RAJAGOPALA AYYANGAR, J.

This revision by an assessee raises for consideration among others the scope and function of rules 4 and 16 framed under the Madras General Sales Tax Act in the scheme of taxation of untanned hides and skins. The assessee, which is a firm, was a dealer-tanner in hides and skins, and held a licence under section 5 of the Act and the rules framed thereunder. Under the rules the tax is levied on a purchaser, and that was the manner that the assessee's turnover was computed. Among the items included in this turnover, as it finally emerged from the Sales Tax Appellate Tribunal, was a turnover in respect of purchases in hides and skins from Bombay by the assessee to the value of Rs. 2, 72, 205-8-3. In regard to this, the contention of the assessee before us was that the amount was not liable to tax under rule 16(2) of the Turnover and Assessment Rules, since the provision was, it was contended, so framed as to impose a tax liability only when the purchase was from a dealer who was licensed under the Madras General Sales Tax Act, and that a purchase from an unlicensed dealer was not liable to the included in the turnover of a tanner-assessee. The argumen