The main and the substantial point raised on behalf of the assessee, the petitioner in this revision petition, relates to the question as to whether the Deputy Commissioner exercising the powers of revision under section 32 of the Madras General Sales Tax Act of 1959 (referred to as the Act in this judgment), is entitled to revise the order of the assessing authority where the latter has not communicated the order of assessment to the assessee.

The assessee, Messrs. A.M. Safrulla & Co., are dealers in hides and skins. In respect of the year of assessment 1954 — 55, the Assistant Commercial Tax Officer by his order, dated 12th October, 1959, held that in view of the decision of the Madras High Court in Noor Mohammed’s case1, no portion of the turnover was liable to assessment to sales tax, as the petitioner was a non-licensee. As the order of assessment did not result in any tax liability, consequent upon the net turnover being determined as nil, this order of the Assistant Commercial Tax Officer was not communicated to the assessee and no demand under section 8-B (2) or 3 (2) of the Act of 1939 was issued to the assessee. After the decision of the Supreme Court, in St