ETHURAMAN, J.

This revision petition has been filed against the orders of the Sales Tax Appellate Tribunal dated 23rd August, 1975, for the assessment year 1954-55. This case has had a very long and chequered history and it is necessary to state the facts from the commencement of the case to the extent relevant in order to appreciate the point involved.

The assessee is a partnership firm, which did not take out a licence under section 5 of the Madras General Sales Tax Act, 1939, in respect of the dealings in hides and skins. Under section 3 of that Act, every dealer was liable to pay for each year tax on his total turnover for that year calculated at two per cent of such turnover. Section 5 of that Act provided that the dealer in hides and skins, whether tanned or untanned, should be liable to tax on single point basis at the prescribed point subject to such restrictions and conditions as may be prescribed, including the conditions as to licences and licence fees. In the case of an unlicensed dealer, the question arose whether he was liable to multi-point tax.

In M. A. Noor Mohamed and Co. v. State of Madras this Court held that an unlicensed dealer in untanned hides and s