SETHURAMAN, J.

These are two appeals against the order of the Board of Revenue dated 21st February, 1977, in a suo motu revision in the cases of two assessees. One of the assessees is known as C. A. Akhtar & Company dealing in hides and skins. The taxable turnover determined by the assessing officer included a sum of Rs. 4, 97, 320.26 relating to the sales of dressed hides and skins which were exported. The assessing authority brought it to tax, but on appeal, the Appellate Assistant Commissioner held that these sales were export sales and allowed the appeal.

Similarly in the case of the other assessee, Shafeeq Ahmed & Company, the taxable turnover included Rs. 18, 81, 949.43 representing the sales of dressed hides and skins which were exported. In this case also, the amount had been brought to tax as if they were local sales. But on appeal, the Appellate Assistant Commissioner held that the turnover represented sales in the course of export and hence was exempt from tax.

The orders of the Appellate Assistant Commissioner were examined by the Board in the light of the decision in Mod. Serajuddin v. State of Orissa and the decisions of this Court in State of Tamil Nadu v. A