2026:APHC:8866 APHC011354212007 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI [3529]

(Special Original Jurisdiction)

MONDAY, THE TWENTY THIRD DAY OF FEBRUARY TWO THOUSAND AND TWENTY SIX PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR TAX REVISION CASE Nos.: 111/2008 & 26/2009 TAX REVISION CASE NO: 111/2008 Between:

1. THE STATE OF ANDHRAPRADESH, AP ...PETITIONER AND

1. KUSUMANCHI RAMESHWARA RAO TRADERS, AP ...RESPONDENT Counsel for the Petitioner:

1. GP FOR COMMERCIAL TAX Counsel for the Respondent:

1. S R R VISWANATH The Court made the following Common Order:

(per Hon’ble Sri Justice R. Raghunandan Rao)

Both these Revision Cases arise out of a common order of the Sales Tax Appellate Tribunal, Visakhapatnam Bench, dated 27.09.2007. They are being disposed of by way of this common order, as the issues raised in both these cases are common.

2. In both these cases, the respondent dealers, being processing agents, were purchasers of raw cashew nuts from cashew nut farmers in the State of Andhra Pradesh and had dispatched these cashew nuts to their non- resident principals, out of the State, for the relevant assessment years. The respondent dealers