ISMAIL, C.J.

All these cases involve the same point and are therefore disposed of by a common judgment. The petitioner in T.C. Nos. 894 and 895 of 1977 is one and the same and these tax revision cases are concerned with assessment under the Tamil Nadu General Sales Tax Act and the Central Sales Tax Act for the year 1973-74. The tax revision cases have been preferred against the order of the Board of Revenue (Commercial Taxes), Madras, dated 26th February, 1977, suo motu revising the order of the Appellate Assistant Commissioner, Kancheepuram. T.C. No. 591 of 1979 has been preferred by the State against the order of the Tamil Nadu Sales Tax Appellate Tribunal (Main Bench) dated 14th December, 1978, in respect of the assessment for the year 1976-77 dealing with another assessee. W.P. Nos. 4951 and 4952 of 1978 have been filed by the same assessee praying for the issue of a writ of prohibition. The two writ petitions have been filed, one in respect of the assessment under the Tamil Nadu General Sales Tax Act and the other with reference to the assessment under the Central Sales Tax Act. The prayer in the writ petitions is for the issue of a writ of prohibition restraining the Joint Commercial Tax Officer, Mannadi (East), (impleading the State of Tamil Nadu also as the second respondent), from proceeding further with his notice for reopening the assessment during the year 1972-73 and seeking to tax the goods in question as goods liable to multi-point levy of sales tax. The facts leading to these cases can now be stated as follows :

In T.C. Nos. 894 and 895 of 1977, the Deputy Commercial Tax Officer held that the scraps of hides and skins were not eligible to single point levy and, therefore, brought them to tax at multi-point levy. On the other hand, with regard to coloured leather, he held that, notwithstanding the colouring they continued to be dressed hides and skins and, therefore, liable to single point levy as provided for under sections 14 and 15 of the Central Sales Tax Act. When the assessee preferred appeals to the Appellate Assistant Commissioner, the Appellate Assistant Commissioner took a different view. He accepted the contention of the assessee that even leather splits would continue to be hides and skins and, therefore, were liable only to single point levy. It was this order which was revised by the Board of Revenue. The Board of Revenue took the view that leather splits were merely scraps, that they could not be termed as hides and skins and that, therefore, the turnover relating thereto was liable to multi-point levy. With regard to the coloured skin, the Board of Revenue took the view that as a result of colouring and dyeing what was produced was a different commercial commodity other than hides and skins and that, therefore, the same would not fall within the scope of section 14(iii) of the Central Sales Tax Act. It is this conclusion of the Board of Revenue that is challenged in the tax revision cases.As far as T.C. No. 591 of 1979 is concerned, the Sales Tax Appellate Tribunal held that coloured leather would also come within the scope of section 14(iii) of the Central Sales Tax Act and that, therefore, the turnover was liable to only single point levy. The correctness of this conclusion is challenged by the State in this tax revision case.

The two writ petitions, as we already pointed out, have been filed for the issue of a writ of prohibition. Originally, the Deputy Commercial Tax Officer taxed the turnover relating to coloured skins at single point on the basis that they would still be hides and skins as contemplated under section 14(iii) of the Central Sales Tax Act. Subsequently, he changed his opinion and proposed to tax the turnover at multi-point on the ground that coloured leather would not fall within the description of hides and skins as contained in section 14(iii) of the Central Sales Tax Act. Putting forward the contention that the assessing authority was in error in taking such a view