Judgment :- Ismail, J. All these three revision petitions are by the same petitioner and they relate to three different assessment years, namely 1966-67 to 1968-69. The assessments were under Central Sales Tax Act, 1956. The petitioner claimed exemption from tax under the Central Sales Tax Act in respect of the turnover in question. With regard to the facts, the Tribunal states as follows :- "The appellants purchased raw hides and skins within the State tanned them and sold them inter-State. No doubt, in respect of the locally purchased raw hides and skins, they have suffered tax at the purchase point as per item 7(a) of the Second Schedule. It is not the case of the appellants that in respect of the inter-State sales in question they are with reference to the raw hides and skins. The inter-State sales in question they are only with reference to the sales of tanned hides and skins. It is not the case of the appellants that the tanned hides and skins sold inter-State had suffered tax as tanned hides and skins within the State. What the appellants claim is that because locally purchased raw hides and skins had suffered purchase tax under item 7(a) of the Second Schedule, proportionate exemption has to be given in respect of inter-State sales of tanned hides and skins." * For the purpose of understanding this claim of the petitioner and the rejection thereof by the Tribunal it is necessary to refer to certain statutory provisions. 2. S. 14 of the Central Sales Tax Act, 1956, enumerates certain items as goods which are of special importance in inter-State trade or commerce. Item (iii) of S. 14 is as follows : "(iii) hides and skins, whether in a raw or dressed state;" S. 15 of the Central Sales Tax Act provide : "Every sales tax law of a State shall, in so far as it imposes or authorises the imposition of a tax on the sale or purchase of declared goods, be subject to the following restrictions and conditions, namely : (a) the tax payable under that law in respect of any sale or purchase of such goods inside the State shall not exceed three per cent. (as it stood on the relevant date) of the sale or purchase price thereof, and such tax shall not be levied at more than one stage; (b) where a tax has been levied under that law in respect of the sale or purchase inside the State of any declared goods and such goods and such goods are sold in the course of inter-State trade or commerce, and the tax has been paid under this Act in respect of the sale of such goods in the course of inter-State trade or commerce, the tax levied under such law shall be reimbursed to the person making such sale in the course of inter-State trade or commerce in such manner and subject to such conditions as may be provided in any law in force in that State." * In order to give effect to these provisions of the Central Sales Tax Act, S. 4 of the Tamil Nadu General Sales Tax Act, 1959, has been enacted as follows : "Notwithstanding anything contained in S. 3, the tax under this Act shall be payable by a dealer on the sale or purchase inside the State of declared goods at the rate and only at the point specified against each in the Second Schedule on the turnover in such goods in each year, whatever be the quantum of turnover in that year." * S. 4-A of the Tamil Nadu Act gives effect to S. 15 (b) of the Central Sales tax Act. Pursuant to the provisions contained in S. 4 of the Tamil Nadu Act, the Second Schedule to the Tamil Nadu Act, deals with hides and skins as item 7 (a) and (b) and they are as follows :S.N. Description of goods. Point of levy Rate of tax 7(a) Raw hides and skins At the point of last purchase in the State. 3% (b) Dressed hides and skins At the point of (which were not subject first sale in to tax under this Act the State 1 1/2% as raw hides and skins.) The Governor of Tamil Nadu in exercise of his powers under sub-S. (5) of S. 8 of the Central Sales Tax Act, 1956, has issued the following notification : DECLARED GOODS INTER - STATE SALES EXEMPTION (MADRAS). (G.O. No. 3602, Revenue 28th December, 1963) III No. 56 of 1964 : In exercise of the powers conferred by sub-S. (5) of S. 8 of the Central Sales tax Act, 1956 (Central Act 74 of 1956), the Governor of Madras hereby directs that in respect of all declared goods sold in the course of inter-State trade or commerce, no tax under the said Act shall be payable by any dealer, where tax has been levied and collected in respect of the sale or purchase of such declared goods under S. 4 of the Madras General sales Tax Act, 1959 (Madras Act 1 of 1959), subject to the following conditions, namely : (i) the burden of proving that the tax under S. 4 of the Madras General Sales Tax, 1959 (Madras Act 1 of 1959) has been levied and collected in respect of any such declared goods shall lie on the dealer; and (ii) the dealer shall not claim refund under clause (b) of S. 15 of the Central Sales Tax Act, 1956 (Central Act 74 of 1956) of the tax levied and collected under S. 4 of the Madras General Sales Tax Act, 1959, from the dealer or such tax has not been refunded to him." 3. It is based on these provisions, the petitioner claimed before the taxing authorities and the Tribunal that the petitioner was not liable to pay tax under the Central Sales Tax Act, 1956, in respect of the inter-State sales of tanned hides and skins effected by it, because it had paid tax under S. 4 of the Tamil Nadu General Sales Tax Act, 1959 4. There will be no order as to costs.