RAMANUJAM, J.

The assessee in this case purchased the old superstructures, belonging to Life Insurance Corporation of India, one situated at Broadway and the other at Dr. Guruswamy Road, for Rs. 1, 00, 000 and Rs. 77, 666.66 respectively, on the understanding that the said superstructure would be demolished and the debris would be removed. The assessee, after demolishing the superstructures, had sold the old iron and timber materials. The assessee is also a dealer in old iron scrap materials. On the sales of old iron and timber materials by the assessee, the assessee was assessed on a taxable turnover of Rs. 1, 78, 026.62 for the assessment year 1973-74, under the Tamil Nadu General Sales Tax Act. The assessee contended that his sales of old iron and timber materials are second sales inside the State, the first sales being by the Life Insurance Corporation of India, and therefore he is not liable to be taxed on this sales of old iron and timber materials got out of the demolition of the superstructures purchased from the Life Insurance Corporation of India. The assessing authority finalised the assessment on the basis that the assessee is the first seller of the old iron