V. RAMASWAMI, J.

Soundamman Textiles, Komarapalayam, was a partnership firm carrying on business in the manufacture and sale of handloom cloths. For the assessment years 1960-61 to 1963-64, accepting the returns filed by the firm, the Deputy Commercial Tax Officer, Tiruchengode, assessed the firm and collected the tax. Long after that, the assessing officer reopened the assessment for the said years on the ground that certain sale of imported silk yarn and dyes were also liable for sales tax as they were not utilised in the manufacture of handloom cloth. After following the procedure, the assessing officer made a reassessment order on 25th March, 1966 in respect of the assessment year 1960-61 and on 31st March, 1966 in respect of the three assessment years, namely, 1961-62, 1962-63 and 1963-64. The same assessing officer assessed the firm for 1964-65 also on 21st February, 1966. The assessing officer also levied penalties under section 12(3) of the Tamil Nadu General Sales Tax Act, 1959, hereinafter referred to as "the Act", in respect of the assessment years 1960-61 to 1963-64 and under section 16(2) of the Act in respect of the assessment year 1964-65. The firm preferr