ORDER H. S. KAMATH, PRESIDENT - This application for revision has been pressed on two grounds. 2. The first is that the sale price amounting to Rs. 635-2-6 of certain articles like shovels, screws, hammers, etc., sold to the Nagpur Electric Supply Co., should be excluded from the turnover under clause (a)(iii) of Section 2(j) of the Act. The claim for exclusion can be justified only if these goods were used by the Electric Supply Co., in the generation or distribution of electrical energy. The Commissioner held in the negative. The question whether the goods mentioned are required for use or were used in the generation or distribution of electrical energy is not a question of law, much less is it a substantial question of law. On this ground, therefore, revision does not lie. 3. The second ground is that the sale price of goods supplied to customers "on approval" and returned by them as not approved should be excluded from the turnover. The amount involved is Rs. 10,289-10-9. The facts concerning this ground do not seem to be in dispute. In fact, the Commissioner's order suggests that he would have allowed the exclusion, had the present Rule 5(iv) of the rules made under the Act been in existence during the period to which this assessment relates. What apparently has escaped the notice of the learned Commissioner as also of the learned counsel, who represented the applicant before me, is Section 24 of the Sale of Goods Act, the principles of which are more or less embodied in Rule 5(iv). Even in the absence of Rule 5(iv), Section 24 applies to cases of goods supplied "on approval". On this ground, therefore, the application succeeds, so far as the point of law urged is concerned. As to the exact amount qualifying for exclusion, I do not propose to give a decision in these proceedings. That decision should be given by the Commissioner, to whom I remand the case, after examining the particulars of each of the transactions involved, in order to see whether it is covered by the provisions of Section 24 of the Sale of Goods Act, read with Rule 5(iv), referred to above. Ordered accordingly.