Heard both.

2. The petitioner is a registered dealer in iron and steel products on the file of the respondent under the provisions of the Tamil Nadu General Sales Tax Act, 1959 (hereinafter called the Act). For the assessment year 2003-04, the petitioner reported a total and taxable turnover of Rs.78.76 crores and Rs.54.43 lakhs respectively. The respondent, on verification, issued a notice proposing to disallow the entire claim of second sale exemption on the basis of certain purchases effected from four registered dealers for Rs.3.05 crores.

3. The petitioner filed their interim objections requesting the respondent to furnish copies of the records and the statements relied upon in the notice, afford an opportunity for cross examination of the third parties, whose records were relied upon with the accounts of the dealer and grant sufficient time to file objections on receipt of the records sought for and opportunity in the matter.

4. The respondent, however, did not accede to the request made by the petitioner, but completed the assessment by passing the impugned order dated 31.3.2005 and confirmed the proposal in the pre-revision notice. This order of assessment has been chal