JAGADISAN, J.

The petitioner is the sole proprietor of a business at Madurai run in the name and style of Sri Kittappa Dress Manufacturing and Embroidery Works. He is a "dealer" in textiles, within the charging provisions of the Madras General Sales Tax Act. He is dealing in ready-made garments, silk choli bits and saris. In the year 1955-56 he carried on business between 1st April, 1955, and 16th May, 1955, and again from 12th July, 1955, to 31st March, 1956. For that year he returned his turnover of sales as Rs. 95, 600-8-3. The Deputy Commercial Tax Officer, Madurai Town III, scrutinised the account books of the petitioner and found that the net turnover of the petitioner was as follows : (1) Ready-made garments - Rs. 19, 165-4-3; (2) First sales of silk choli bits - Rs. 74, 471-0-9; (3) First sales of saris - Rs. 2, 013-15-6; total Rs. 95, 650-4-6. In respect of the sales turnover of the ready-made garments the tax was levied at the rate of 3 pies per rupee, but in respect of the sales turnover of "choli" bits and saris, tax was levied at the rate of Re. 0-1-6 per rupee. The petitioner contended before the Deputy Commercial Tax Officer, Madurai Town, that the levy of