VEERASWAMI, C.J.

This batch of petitions raises the validity of item 7(a) and (b) in the Second Schedule to the Madras General Sales Tax Act, 1959. In Writ Petition No. 734 of 1970 the petitioner is a dealer in hides and skins, whose turnover for the assessment year 1968-69 was determined which consisted of purchases of raw hides and skins, as well as of tanned hides and skins, goat and sheep hair sales and purchase of tanning materials. A smaller amount of the turnover related to kasar sales. But we are concerned only with the first two types of turnover. The first transaction of purchase of raw hides and skins included both local purchases, as well as inter-State purchases. The second comprised of local and export sales of tanned hides and skins. The local purchases of raw hides and skins amounted to the value of Rs. 68, 20, 377.15 and inter-State purchases of similar goods were valued at Rs. 41, 11, 618.33. Local sales of hides and skins accounted for a turnover of Rs. 75, 047. No question arises as to export sales of similar goods. The locally purchased raw goods had gone into the tanned hides and skins exported. There was no means of finding out from the accounts of the assessees as to how much of the raw hides purchased locally had gone into tanned hides and skins which were exported. The assessing authority, therefore, estimated the proportionate value of the raw goods used in tanned goods exported.

It is not contended that the local purchases of raw hides and skins are not liable to tax under item 7(a) of the Second Schedule at the prescribed rate of tax. But it is said that (1) sections 4, 6 and 9 of the Act in so far as they charge inter-State sales are invalid, and (2) that item 7(b) being violative of article 304(a) of the Constitution, it is invalid, and if that be so, clause (a) of item 7 is not severable and should, therefore, fall with clause (b). We find no substance in the first of the grounds. Only we have got to read the language of the three sections to reject the contention. None of those sections charges inter-State sales. It was pointed out that an inter-State sale was equated to an inside sale and on that basis, it should be taken that these sections charged also inter-State sales. We do not think that any case has laid down that proposition that an inter-State sale is also an inside sale. But what has been held by this court is that for the purpose of giving a locus to an inter-State sale, with reference to the components of sale, the concept of inside sale has been adverted to, but not to equate inter-State sale to a local or intrastate sale.The other ground as urged by the counsel for the petitioners derives much of its support from Firm A. T. B. Mehtab Majid & Co. v. State of Madras In the scheme of single point taxation of declared goods as envisaged in the Act and item 7(a) and (b) in the Schedule thereto raw hides and skins are charged at the point of last purchase in the State at the rate of 3 per cent. and dressed hides and skins which have not been subjected to tax under the Act as raw hides and skins are charged at the point of first sale in the State at the rate of 1 1/2 per cent. That would imply, particularly in the context of sections 14 and 15 of the Central Sales Tax Act, that hides and skins, whether at the raw or dressed state, should be subjected only to a single tax. Therefore, if raw hides and skins locally purchased have suffered tax, necessarily it would mean that dressed hides and skins made out of such raw hides and skins will not be liable to tax. Freedom from tax of sales of dressed hides and skins would depend on the corresponding raw hides and skins having suffered tax at the purchase stage in the State. When out of imported raw hides and skins, tanned hides and skins are made, which are sold locally, such sales at the point of the first sale are liable to charge. In such circumstances, the contention for the petitioners is that, whereas dressed hides and skins s