Rajagopala Ayyangar, J.- Messrs. Mettur Industries, Ltd.. are the petitioners in this Tax Revision Case. These proceedings arose out of the assessment for the year 1951-1952. The Deputy Commercial Tax Officer, ascertained the net assessable turnover of this assessee at Rs. 2,40,87,084-0-7. Objections were taken to this assessment by the assessee and an appeal was filed to the Commercial Tax Officer, but that appeal was dismissed. The objections were repeated in a further appeal by the assessee to the Tribunal.

The objections taken by the assessee fell under three heads: (1) a sum of Rs. 23,66,029 claimed to be the turnover arising from inter-state sales, the exemption claimed being under Article 286(2) of the Constitution; (2) Rs. 19,41,362 being the turnover on the purchase value of cotton purchased by the mills from Messrs. Volkart Brothers; and (3) Rs. 2,24,517 being the sales-tax collections made by the appellant, to the inclusion of which in the assessable turnover objection was taken. The first item of the claim under the head of exemption by reason of the sales being of an inter-State character was allowed by the Tribunal, and is no longer in dispute before us. The third of t

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