Burden to prove commission-agent status under sales tax law failed, so dealer classification and tax liability were sustained.

Section 8 placed the burden on the petitioners to prove that they acted as commission agents and satisfied the statutory requirements for that status. The record did not show fixed remuneration, the requisite accounts, or other material bringing them within the section. On that basis, the finding that they were dealers could not be disturbed, and the tax liability was sustained against them.

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Issues: Whether the petitioners had proved that they were commission agents and not dealers so as to avoid liability under Section 8 of the General Sales Tax Act.

Analysis: Section 8 placed the burden on the petitioners to establish that they acted as commission agents and satisfied the statutory requirements. The record did not show that they had discharged that burden before the courts below. There was no sufficient material to show that they acted for fixed remuneration, maintained the requisite accounts, or otherwise brought themselves within the scope of Section 8. In the absence of such proof, the finding that they were dealers could not be disturbed.

Conclusion: The petitioners failed to prove that they were commission agents, and the tax was validly sustained against them.

Ratio Decidendi: Where a taxing statute places the burden on the claimant to prove an agency status or exemption, failure to establish the statutory requirements leaves the assessment undisturbed.

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