( 1 ) PRESENT revision Under Section 11 of the U. P. Sales Tax Act, 1948 (hereinafter referred to as "the Act") is directed against the order of Tribunal dated December 21, 1991 for the assessment year 1980-81.

( 2 ) APPLICANT was carrying on the business of palm oil and edible oil. At the time of assessment proceedings Under Section 7 read with Rule 41 (7), applicant had disclosed the sales of U. P. purchased oil for Rs. 6,67,500. 78 and claimed exemption on such sales on the ground that in respect of such goods, applicant was neither importer nor manufacturer. Applicant had made purchases for Rs. 6,36,270 and admittedly, a list of purchases was filed, in which name of the parties and address were mentioned. Assessing authority had passed the assessment order under rule 41 (7) on March 27, 1984 and allowed the exemption on the turnover of Rs. 6,67,500. 78 on the ground that it was related to U. P. purchased goods. It appears that after passing assessment order, the assessing authority had started making the enquiry from the respective assessing authority of the seller about the genuineness of the seller party and about the sale made by them. One of the letter No. 8