The order of the Appellate Division should be reversed insofar as appealed from, with costs.
On this appeal by the State Tax Commission the only question before us is whether the cylinders, which the petitioner uses to deliver gas to its customers, were purchased for resale so as to be exempt from the sales tax at the time of purchase (Tax Law, § 1105, subd [a]; § 1101, subd [b], par [4]).
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