RAJAGOPALA AYYANGAR, J.

This is a revision petition filed by the assessees against the order of the Sales Tax Appellate Tribunal.

The assessees are dealers, among others, in pepper having their head office at Bombay and a branch at Kozhikode. In respect of their turnover for the assessment year 1950-51 they submitted returns in form A-3 disclosing sales to the extent of Rs. 3, 94, 788-11-0 to the Deputy Commercial Tax Officer, Calicut, who was the assessing officer. Out of this figure they claimed exemption in respect of a turnover of Rs. 4, 054-1-9. They also produced their ledger, day book, journals etc., to the assessing officer who checked up their accounts and substantially accepted their return and assessed them on a net turnover of Rs. 3, 93, 486-13-6 by his order dated 15th December, 1951. Subsequently the Commercial Tax Officer, Malabar North, called for and examined the record of the assessment order passed by the Deputy Commercial Tax Officer under section 12(1)(i) of the Madras General Sales Tax Act and finding that certain sales effected by the assessees which had been disclosed in their accounts had been incorrectly treated as not liable to inclusion in thei