BALASUBRAHMANYAN, J.

This is a revision by the State Government against an order of the Sales Tax Appellate Tribunal. The assessee in this case is a partnership firm called Rafeeq Ahmed and Company. They were dealers in skins. They entered into certain transactions of export of hides and skins, putting them through a concern called Abdul Shukoor and Company. They contended that the turnover of Rs. 89, 59, 712 handled by Abdul Shukoor and Company constituted sales in the course of export and those sales were their own sales effected by Abdul Shukoor and Company as their commission agents. The assessing authority did not accept this contention, but held that the assessee had sold these goods to Abdul Shukoor and Company, who, in turn, sold them to the foreign buyers. In that view, the assessing authority brought the sales to tax. The matter was taken in appeal, where the Tribunal ultimately held, agreeing with the assessee's contention, that the turnover in question constituted sales in the course of export and hence not liable for sales tax. The matter was then taken up by the State Government in revision before this Court. There, a Bench of this Court, after some conside