The question of law which has been referred for consideration of the Full Bench is :-

"Whether rule 14 of the Madras General Sales Tax Rules is valid and if so, whether the powers of revision thereunder can be exercised in cases to which rule 17 relating to escaped assessment is applicable ?" *

In view of the fact that the appeals themselves will be posted for final disposal after the receipt of the opinion of the Full Bench on the question of law formulated by the referring Judges we do not propose to deal in any detail with the facts of either of these cases but merely answer the legal question propounded in the order of reference.

The following facts however have to be set out to understand the complaint of the assessees. Both the suits out of which these appeals arise were filed by the assessees for the refund of sales tax paid by them as a result of reassessment in the exercise of revisional powers and in each of them the assessees have succeeded. O.S.A. No. 62 of 1951 relates to an assessment for the year 1944-45. The Deputy Commercial Tax Officer, Harbour Division, who was the assessing authority, by his order dated 27th March, 1946, determined the total turnover o