BALASUBRAHMANYAN, J.

The appellants in these two appeals are different. Each of them is an assessee under the Tamil Nadu General Sales Tax Act, 1959. Each of them owns a ginning factory in which raw cotton or kapas is converted into lint or ginned cotton. As if by a coincidence, each of them does not keep any accounts at all of his purchases. But the commercial taxes department was able to obtain figures of the sales of ginned cotton or lint. Cotton, in any form, is not assessable at the point of sale, which may be one reason why these people have not kept their accounts of purchases. For want of figures of purchases, the assessing authority was hard put to it to estimate the purchase value of raw cotton by applying a formula and arriving at their purchase value from the data furnished by the sales turnover of ginned cotton. In arriving at the purchase turnover from the data available in regard to the sales turnover, the purchase turnover was arrived at in the following fashion, to take the assessment order in the first case :

Estimated purchase value of kapas taken as the last purchase Rs. 2, 83, 601.57

Add loss of kapas in the process of ginning estimated at Rs. 2, 92, 0