Rajagopalan, J.-These are petitions under Article 133 of the Constitution for leave to appeal to the Supreme Court against the decision of this Court in T.R.Cs Nos. 51 and 52 of 1953.

The petitioners are manufacturers of groundnut oil, registered as such under rule 18(1) of the Madras General Sales Tax (Turnover and Assessment) Rules As dealers liable to pay sales tax under Madras General Sales Tax Act IX of 1939, the petitioners elected to be assessed under rule 13 of the Madras General Sales Tax (Turnover and Assessment) Rules. Thesee rules provided for a provisional assessment month by nonth on the basis of the returns submitted by the assessee (see rule 15(2) and 15(3) or for provisional assessment on the best judgment basis (see rule 15(4)). The rules also provided for a final assessment after the close of the year (see rule 13(5) and (6)). The petitioners submitted their returns month by month for the first nine months of 1950-51, but the assessing authority, instead of dealing with the return of each month, made a consolidated provisional assessment for nine months. The assessees claimed relief under rule 18(2) of the Turnover and Assessment Rules, but that claim was negative

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