Y. BHASKAR RAO, J. ( 1 ) THIS revision petition is filed under Section 23 (1) of the Karnataka Sales Tax Act, 1957 and rule 31 (1) (a) of the Karnataka Sales Tax Rules, 1957, against the order dated March 1, 1995 passed in T. A. No. 206 of 1987 on the file of the Karnataka Appellate Tribunal, Bangalore, dismissing the appeal and confirming the order passed in KST/ SMR/36-86-87 dated December 18, 1988, on the file of the Deputy Commissioner of Commercial Taxes, Bangalore. ( 2 ) THE petitioner herein is engaged in the business of dry fish, fish manure and fish oil and registered as a dealer under the provisions of the Act. For the assessment year 1979-80, the assessing authority passed the assessment order on September 30, 1985. While passing the said assessment order, the assessing authority exempted the purchase value of fish oil made from unregistered dealers and sold in the course of export against H declaration forms. The assessing authority granted exemption on the ground that the assessee-petitioner acted as purchase commission agent and he made purchases of fish oil only for and on behalf of registered dealer, viz. , Bawa Fish Meal and Oil Co. , Mangalore, and has purchased fish oil to the tune of Rs. 2,81,638. 24. ( 3 ) THE Deputy Commissioner of Commercial Taxes as he then was, initiated proceedings under section 21 (4) of the KST Act to revise the assessment order stating that the assessment order is improper, illegal and prejudicial to the interests of Revenue, as the exemption is wrongly granted to the petitioner. A notice was issued and a reply was filed by the petitioner in response to the notice and thereafter, the revisional authority made out a case for action under Section 21 (2) of the Act since according to the revisional authority, the commission on a turnover of Rs. 2,81,638. 24 has been wrongly allowed and after following due procedures prescribed under law, directed levy of tax under Section 6 on a turnover of Rs. 1,96,223 and withdrawal of exemption on a turnover of Rs. 2,81,638 and directed to levy accordingly. ( 4 ) AGGRIEVED by the said order, the petitioner filed an appeal under Section 22 (1) of the Act before the Karnataka Appellate Tribunal. The Appellate Tribunal dismissed the appeal. Against that, the present revision petition is filed. 1,96,223 and withdrawal of exemption on a turnover of Rs. 2,81,638 and directed to levy accordingly. ( 4 ) AGGRIEVED by the said order, the petitioner filed an appeal under Section 22 (1) of the Act before the Karnataka Appellate Tribunal. The Appellate Tribunal dismissed the appeal. Against that, the present revision petition is filed. ( 5 ) LEARNED counsel for the petitioner contended that, the petitioner is only a commission agent to purchase fish oil and supplied and sold it to Bawa Fish Meal and Oil Co. , Mangalore, who are the principal purchasers and who have paid the tax. As the petitioner has not purchased and sold directly and only acting as a commission agent in between the vendor and the purchaser of Bawa fish Meal and Oil Co. , it cannot be said that the discharge of duties and transfer of goods from the purchaser as a commission agent will amount to sale. The revisional authority and the appellate authority erred in coming to the conclusion that the sale transaction and the turnover are liable to tax. ( 6 ) THE petitioner's contention is that he was only acting as an agent whose duty is to send the goods from the vendor to purchaser and receive the commission and there is no sale transaction. It is to be noticed that the letter addressed by the petitioner himself to Bawa Fish Meal and Oil co. , indicates the sale by the petitioner to the company. Learned counsel for the petitioner contended that thereafter a clarification letter was issued on October 27, 1986 stating therein that, by mistake and oversight, it is mentioned that it is purchased by the petitioner. But actually the petitioner was acting as a commission agent. That mistake was rectified in the letter dated october, 27, 1986. The original letter written by the petitioner to the company is dated February 17, 1982, Since that date, he has not taken any action to clarify the mistake. The show cause notice was issued on September 5, 1986 and thereafter, the letter dated October 27, 1986 came into existence taking a stand that the assessee is a commission agent. Thus the present letter dated October 27, 1986 is only an afterthought, after the notice is served by the revisional authority. The show cause notice was issued on September 5, 1986 and thereafter, the letter dated October 27, 1986 came into existence taking a stand that the assessee is a commission agent. Thus the present letter dated October 27, 1986 is only an afterthought, after the notice is served by the revisional authority. The original letter dated February 17, 1982 does not show that the petitioner has acted as a commission agent. Therefore, we do not see any ground to interfere. In view of what is stated above, we do not find any merit in this petition. Accordingly, this revision petition is dismissed.