SETHURAMAN, J.

This tax revision case arises out of an order of the Tribunal exempting the turnover in question. Under the Tamilnadu General ST Act, the assessee was finally assessed to tax on a total and taxable turnover of Rs. 1, 59, 291.31 and Rs. 1, 37, 880.15 respectively for the year 1967-68 in the assessment proceeding of the Dy. CTO dt. 3rd September, 1968. On a further scrutiny of the records, the Dy. CTO, Coimbatore, considered that out of the consideration of Rs. 19, 500 for the transfer of the branch at Ooty, the sum of Rs. 18, 929.71 representing sale value of the closing stock held at Ooty branch was wrongly exempted from payment of tax and that it was not eligible for exemption as it did not come within the scope of the provision of r. 6(d) of the Tamilnadu General ST Rules. Accordingly, notice was issued to the assessee calling for its objections, if any, to the proposed revision of assessment. It was contended by the assessee that the business at Ooty branch as a whole was sold, that the branch business was also to be considered as a business as defined under S. 2(d) of the Tamilnadu General ST Act, 1959, and that the sale value of the stock held was eli