SETHURAMAN, J.

This tax revision case has been filed under section 38 of the Tamil Nadu General Sales Tax Act by the State of Madras against the order of the Sales Tax Appellate Tribunal dated 4th December, 1973, holding the assessee to be not liable to tax under the Central Sales Tax Act on a turnover of Rs. 7, 39, 353.14. The assessee is a dealer in non-ferrous metals. In the course of the assessment proceedings the assessing officer noticed that the assessee had effected sales to the Executive Engineer (Public Health), Central Stores, Ernakulam, Cochin-16, on several dates. The assessee sought exemption from tax on the sales on the ground that these sales were effected by transfer of documents within the meaning of section 3(b) of the Central Sales Tax Act and that he had filed E-I and D forms in respect of the same. The assessing officer found that the filing of D forms from the Government departments did not satisfy the requirements of the Act as the State Government departments were not registered dealers. Since all the sales were to the Government departments, he issued notices to the assessee asking for its objection to the proposed assessment of the said turnove