ORDER The petitioner challenges the order of the 2nd respondent who is the Agricultural Income-tax and Rural Sales Tax Officer, Perumbavoor, levying sales tax on purchases of cashew-nuts made by the petitioner in the State for the periods from 1-1-1125 to 29-5-1950 and from 30-5-1950 to 31-3-1951. One of the grounds of the challenge is that these purchases were made by him on behalf of two principals who are both of them exporters of cashew kernels to America. The other ground on which the assessment is challenged is that under Section 9 of the Travancore-Cochin General Sales Tax Act, XI of 1125, agents licensed to make purchases on behalf of known principals cannot be taxed. 2. So far as the first ground is concerned learned Counsel for the petitioner does not press it in view of the decision of the Supreme Court in State of Travancore-Cochin v. The Shanmugha Vilas Cashew-nut Factory ([1953] 4 S.T.C. 205), which decided that purchases made and completed locally, though meant for subsequent export, are liable to State sales tax. 3. As regards the other ground there is no averment in the petition or the affidavit that the petitioner is a licensee under Section 9 of the Sales Tax Act. What is alleged is merely that he had applied for a licence. The petitioner will not become a licensee, immune from the levy of sales tax under Section 9 on him mere making an application for a licence. The section exempts only persons who are licensed by the Government. Therefore, this ground also is not available to the petitioner. There is no provision in the Sales Tax Act to the effect that when an application for a licence is made and no orders are issued thereon within a specified time, licence must be deemed to have been granted, like the provision that is found in certain Municipal Acts. 4. The result is that the petition is without merit and should be dismissed with costs and advocate's fee which I fix at Rs. 100.