ABDUL HADI, J.

This tax revision case is against the order of the Sales Tax Appellate Tribunal deleting a turnover of Rs. 6, 29, 700 from assessment for the assessment year 1977-78 on the ground that it is the turnover coming under rule 6(d) of the Tamil Nadu General Sales Tax Rules (hereinafter referred to as "the Rules"). The said rule provides that in determining the taxable turnover, amounts realised by a dealer by sale of his business as a whole shall be deducted from the total turnover of the dealer. But, it is clear that the Tribunal is wrong in treating the transaction as a sale of assessee's "business as a whole". As per the very finding of the Tribunal, the transaction was only a transfer of certain specific assets of the assessee-company, viz., plant and machinery and car of the above referred to value of Rs. 6, 29, 700 and furniture and fittings to the tune of Rs. 1, 26, 010 and land and buildings to the tune of Rs. 13, 54, 500. So, it cannot be considered as a transfer of "business as a whole", that is, transfer of all the assets and liabilities (or at least of the assets and liabilities of one branch of the assessee's business), as was the case in Deputy Co