Judgment :- SATYANARAYANA RAO, J. The assesses are the Cardamom Marketing Co. Ltd., Bodinayakanur. For the assessment year 1948-49 the turnover for which they were assessed to sales tax was Rs. 6, 20, 500. The assessees claimed that as they sold the goods on behalf of known principals, they should not be made liable to tax under Section 8 of the Sales Tax Act. That was the sole contention, but at the stage of the appeal before the Tribunal, they raised a further question that in any event, in these transactions they acted as a broker and auctioneer and therefore they were not liable. The Tribunal held that in view of the documentary evidence produced before it, it considered that it was not shown that assessees acted as a broker in the sense that they brought together the purchaser and the seller. The sellers, according to the finding of the Appellate Tribunal, were unknown. Among the documents on which they relied on is Ex. A, the register which contained the entries relating to auction maintained by the assesses. In that the signature of the bidder is obtained in token of having verified the actual weight and the signature of the owners are also obtained for the receipt of the sale amount or for authorising payment. There are also Ex. C payment book maintained by the appellants, wherein they entered the acquittance, which they obtained from the seller for the payment of the sale price and Ex. D, the duplicate copy of the Cardamom sales vouchers. On the strength of these documents, the appellants contended that they acted only as brokers. It is not possible to disagree with the finding of the Appellate Tribunal; we ourselves scrutinised some of these documents, and we are satisfied that there is nothing to show that the assessees acted merely as an intermediary to bring about the sale transactions between the owner of the goods and the purchaser. The Tribunal, in our opinion, rightly rejected the contention that the assessees were brokers.The other contention that they were commission agents for known principals, was also negatived by the Tribunal, as some of the principals themselves repudiated the agency of the assessees on their behalf and there were no particulars furnished by the assessees to identify the sellers, so that the department might proceed against them for the tax. It is, therefore, obvious that the assessees failed to establish the contention, that they sold the goods on behalf of known principals, and that they are entitled to the exemption claimed under Section 8 of the Act. All the requirements of the section must be satisfied before the assessees could claim exemption under it, as the object of the provision is to enable the Government to proceed against the principals. It is only in that event that the commission agent would be exonerated from the liability. The decision, therefore, on both the points of the Appellate Tribunal, is correct and must be affirmed. The revision is dismissed with costs Rs. 250. In view of the above discussion, the decision in C.R.P. No. 2110 of 1952 applies also to T.R.C. No. 292 of 1953. It is dismissed but without costs. Petition dismissed.