BALASUBRAHMANYAN, J.

This revision petition under section 38 of the Tamil Nadu General Sales Tax Act, 1959, is brought by E.I.D. Parry (India) Limited, Madras (hereinafter called the assessees), against an order of the Sales Tax Appellate Tribunal, Madras.

The assessees carry on business as distillers. They manufacture methylated spirit, denatured spirit and rectified spirit in their distilleries in the State and sell them to various persons and institutions. The different stages of manufacture and sale of these spirits are governed and regulated by the Rules framed by the State Government under the Tamil Nadu Prohibition Act, 1937. The regulation of the trade, under the relevant Rules, takes the form of a net work of licensing procedures. The system of licences is also at the same time ultilised by the Rules for the purpose of raising revenues for the State. Periodical licence fees on holders of licences are imposition of one kind. Levy of excise duties on spirits at one stage or other in the course of trade forms another source of public revenue. In addition to those exactions, the gallonage fees are levied on the quantity of spirits handled by the trade. The gallonage