RAJAGOPALAN, J.

This application for the issue of a writ of certiorari, preferred under Article 226 of the Constitution, arises out of proceedings taken by the Deputy Commercial Tax Officer, Tirukoilur, to assess the petitioner to tax under the Madras General Sales Tax Act, IX of 1939, for the assessment year 1952-53.

The petitioner was a dealer in grocery with his principal place of business at Ulundurpet within the jurisdiction of the Deputy Commercial Tax Officer, Tirukoilur, in South Arcot District. The petitioner was first assessed to tax on a turnover of Rs. 86, 441-14-9 for the assessment year 1952-53. The assessment was completed by the Deputy Commercial Tax Officer, Tirukoilur, on 10th February, 1954. Proceedings were subsequently taken under rule 17 of the General Sales Tax Rules and on 20th March, 1956, the Deputy Commercial Tax Officer, Tirukoilur, revised the assessment for 1952-53, to include in the assessable turnover of the petitioner a further sum of Rs. 56, 279, which represented the price of chillies sold by the petitioner in Dindigul taluk of Madurai district.

The events that transpired between the two assessments and which led up to the assessment on 2