JAGADISAN, J.

The respondent is a firm of dealers in hides and skins at Madras. They were assessed by the Deputy Commercial Tax Officer, No. 3 Moore Market, to their turnover for the year 1955-56 under the Madras General Sales Tax Act, 1939. The order of assessment was passed on 15th December, 1956. Their assessable turnover was determined at Rs. 11, 47, 315-14-7. They filed an appeal before the Commercial Tax Officer on 15th February, 1957. During the pendency of the appeal, Madras Act I of 1959 came into operation on 1st April, 1959. The appeal was transferred to the Appellate Assistant Commissioner, the prescribed appellate authority under the new enactment. By order of the appellate authority the assessee's turnover was reduced to Rs. 6, 22, 693-13-11. They preferred a further appeal to the Appellate Tribunal disputing a turnover of Rs. 80, 744. This turnover related to sales effected by them through Messrs Beardsell and Co. and they claimed that these sales were in the course of export and therefore not within the ambit of the Act. The Appellate Assistant Commissioner has taken the view in regard to these sales that they were local sales assessable to tax. The Appel