SRINIVASAN, J.

The assessees are dealers in cotton and cotton seeds. The total turnover exceeded Rs. 14, 00, 000, and after deducting the purchase turnover, the net turnover was fixed at Rs. 4, 35, 822. There was no dispute with regard to this turnover. But the claim of the assesses was that a turnover of Rs. 2, 40, 470 brought to tax was the estimated purchase value of cotton sold in the course of inter-State trade. Under rule 20 of the Madras General Sales Tax (Turnover and Assessment) Rules refund of tax was claimed. The assessing authority held that such a refund provided for therein was available only on the submission of certain returns within a prescribed period. Such returns not having been filed, the refund of tax claimed was refused.

Against this order, an appeal was taken to the Appellate Assistant Commissioner. The appellate authority accepted the conclusion reached by the assessing authority that since the conditions prescribed under the relevant rule had not been complied with, the refund could not be granted and that on the facts established, the assessment proceedings could not be impeached.

A further appeal to the Tribunal was also rejected. It is against