Judgment :- ELIPE DHARMA RAO, J. 1. The Tax Case Revision was transferred from the Special Tribunal on its abolition. The Tax Case Revision was admitted on the following substantial question of law :- "Whether the Tribunal, being a final fact finding Authority, is correct in simply extracting the finding arrived at by the lower authorities and confirmed it without independent application of its mind and without reasonableness ? 2. The petitioner is carrying on business in Zandu balm and other Pharmaceuticals items. For the assessment year 1996-97, the petitioner reported taxable turnover as follows : Sales of Medicine from 1.4.96 to 16.7.96 - Rs. 64,19,743.78 Sales of Medicine from 17.7.96 to 31.3.97 – Rs.2,41,32,802.88 Rs.3,05,52,546.66 Accepting the aforesaid total amount as total and taxable turnover, the Commercial Tax Officer, by order dated 30.9.1997, confirmed the aforesaid amount. Against the said order, an appeal was preferred before the Appellate Assistant Commissioner, who, by order dated 20.7.1998, modified the taxable sales turnover to Rs.54,19,743.78, thereby granting exemption to the amount of Rs.2,41,32,802.88 levied between the period 17.7.1996 and 31.3.1997. Aggrieved by the aforesaid order, the Revenue preferred Appeal in S.T.A.No.45 of 1998 before the Tamil Nadu Sales Tax Appellate Tribunal, which, by order dated 07.3.2000, allowed the appeal. The said order came up before the Tamil Nadu Taxation Special Tribunal by Revision. On the abolition of the Tribunal, the matter came to be transferred to this Court as Tax Case. 3. Learned counsel appearing for the assessee has contended that the Sales Tax Appellate Tribunal, while reversing the order of the Appellate Assistant Commissioner, has not assigned any reason for such reversion and has set aside the order in a mechanical manner without any reasonableness. Further he contended that the order of the Tribunal is liable to be interfered with in view of the earlier Division Bench order of this Court in (2011) 39 VST 247 (Mad) [State of Tamil Nadu v. National Time Co.]. 4. Heard the learned counsel for both sides at length and perused the materials on record including the decision relied on by the petitioner. 5. The question arises for consideration is as to whether the petitioner is entitled for exemption from the sales turnover for the period from 17.7.1996 to 31.8.1996? 6. 4. Heard the learned counsel for both sides at length and perused the materials on record including the decision relied on by the petitioner. 5. The question arises for consideration is as to whether the petitioner is entitled for exemption from the sales turnover for the period from 17.7.1996 to 31.8.1996? 6. The contention of the assessee is that in the said financial year as the turnover did not exceed Rupees One Hundred Crores, there would be no liability of additional Sales Tax on the assessee and it is also his further contention that the order of the assessing authority to the extent not having applied the unamended provision, namely, section 2 (1)(a) as it originally stood, wherein first ten lakhs of rupees has to be deducted in the taxable turnover, was liable to be interfered with. 7. In order to appreciate the contentions, we have gone through the order of the Tribunal. As rightly pointed out by the learned counsel for the assessee, the Tribunal has not dealt with the matter in detail and it has failed to discuss the issue as to whether the assessee would be liable to pay additional Sales Tax in the light of amended sections 2(1)(a) and 2(1)(aa). All along, the contention of the assessee is that it is liable for exemption from 01.8.1996 in view of the amended sections and before the end of the year, the taxable turnover has not exceeded Rs. One Hundred Crores. Though the said contention was accepted by the appellate authority, the Tribunal has reversed the said decision without assigning any reason. 8. It is not in dispute that the total turnover of the assessee did not exceed Rupees One Hundred Crores in the financial year 1996-97. It is not in dispute that the amended provisions of Section 2(1)(a) came into effect from 01.8.1996. Therefore, the payment of additional Sales Tax would arise only if the taxable turnover for the whole of the financial year exceeded Rs. One Hundred Crores. Moreover, for the period up to July 31, 1996, the liability has to be worked out as per the provision prevailing on that date, i.e., under unamended Section 2(1)(a) and for the consequent period as per the amended position. This view is amply supported by the earlier Division Bench of this Court in National Time Co. (cited above). Moreover, for the period up to July 31, 1996, the liability has to be worked out as per the provision prevailing on that date, i.e., under unamended Section 2(1)(a) and for the consequent period as per the amended position. This view is amply supported by the earlier Division Bench of this Court in National Time Co. (cited above). In the said decision, while dealing with the effect of amended provision, the Bench observed as follows :- "18. The learned Special Government Pleader fairly pointed out that the unamended provision was very much in force up to July 31, 1996 and calculation of additional sales tax would have to be made by the assessing authority for the taxable turnover which was prevailing only up to the period July 31, 1996 and for the period subsequent to August, 1996 the liability would have been assessed, if at all the taxable turnover up to the end of the financial year exceeded one hundred crores of rupees and otherwise. Consequently, the rate of tax applied, viz., two per cent. was in consonance with the statutory provision as was prevailing as on July, 1996. Since the taxable turnover did not cross Rs.100 crores during the financial year, in the case of the respondent-assessee, the liability of additional sales tax will have to be calculated only for the period upto July 1996 and not beyond and that too, on the taxable turnover that was available up to that date, viz., July 31, 1996." 9. Applying the principle laid down in the aforesaid decision to the case on hand, we have no hesitation in reversing the order of the Tribunal. The Tribunal, without considering the veracity of the aforesaid decision, has come to a wrong decision, which is liable to be set aside. For the reasons stated above, the Tax Case is allowed. No costs.