This is an application for issuing a writ of prohibition directing the respondent to forbear from assessing the petitioner for sales tax for 1950-51, The petitioner is a merchant trading in bullion and specie at Ettayapuram Naduveerapatti in Tirunelveli district. When the Madras General gales Tax Act was passed in 1939 bullion and specie were exempt from taxation. In 1947, section 5 of the old Act was substituted by the Madras General Sales Tax Amendment Act, 1947 (Madras Act XXV of 1947). Under that section the sale of bullion and specie shall be liable to tax only at a single point in the series of sales by successive dealers as may be prescribed and only at the rate of one-fourth of one per cent. of the turnover at that point. In exercise of the powers conferred on the Provincial Government by section 19 of the Act, rules were made for licensing the persons engaged in the sale of goods and the imposing of conditions in respect of the same or purpose of enforcing the provisions of the Act and the fee for licences. Rule 5(1)(d) and (f) of the Madras General Sales Tax Rules, 1939, requires that every person who deals in bullion and specie should submit an application in for