RAMASWAMI, J.

The petitioners are dealers in cotton yarn at Salem in the State of Tamil Nadu. In their return under the Central Sales Tax Act for the assessment year 1963-64, they claimed exemption among others on a turnover of Rs. 2, 50, 439.17 on the ground that they were second inter-State sales effected by them by transfer of documents of title to the goods during their movement from one State to another in pursuance of the earlier sales falling under section 6(2) of the Central Sales Tax Act, hereinafter referred to as the Act. In respect of another turnover of Rs. 4, 47, 911.75, which also related to second inter-State sales by transfer of documents of title to such goods during their movement from one State to another, the petitioners claimed that in view of section 15 of the Act, they were not liable for Central sales tax. Since these two items were alone disputed in this revision petition, it would be enough if we note the facts relating to these two items and the findings of the assessing authority, the Appellate Assistant Commissioner and the Tribunal.

The first item of transaction took place in the following circumstances : The petitioners purchased cotton yar