RAMAKRISHNAN, J.

The assessee is a registered dealer in wool at Vaniyambadi. Out of his turnover in 1959-60, the sum in dispute before us is Rs. 2, 08, 343-45 nP. which represents the sales effected to registered purchasing dealers in Punjab. On the ground that the C Forms supplied by the purchasing dealers in the Punjab, and filed by the assessee for the inter-State sales effected by him, did not comply with the rules, he was assessed at 7 per cent. on these sales and was denied the benefit of assessment at the lower rate of 1 per cent. The specific ground on which the benefit of lower rate of assessment was denied was that the C Form contravened rule 10(1) of the rules framed by the Madras State under the Central Sales Tax Act. The rule states that no single declaration shall cover more than one transaction of sale. Apparently the Punjab purchasing dealers gave C Forms in which they have included all the purchases effected by them from the Madras dealer during the year of assessment. The appeal to the Appellate Assistant Commissioner as well as to the Appellate Tribunal failed and the assessee has come before this Court in revision.

Learned counsel for the petitioner-as