Judgment

HIDAYATULLAH, J. : These five appeals on certificates granted by the High Court of Madras were consolidated and heard together. They arise out of proceedings against the appellants under the Madras General Sales Tax Act, 1939. The appellants are three Companies carrying on business of sale of motor cars, motor car spare parts, and other goods. Messrs. George Oakes (Private) Ltd., have filed Civil Appeals Nos. 1 to 3 of 1961 questioning a part of the sales tax imposed on them for the years, 1950-51, 1951-52 and 1952-53. Civil Appeals Nos. 4 and 5 of 1961 have been filed respectively by Messrs. Addison & Co. (Private) Ltd., an Messrs. Rane (Madras) Ltd., questioning similarly a part of the tax imposed on them for the year ending March 31, 1952. The common question which has been raised by the appellants arises in the following circumstances.

2. Under the Madras General Sales Tax Act, 1939, "turnover" is defined inter alia as-

"the aggregate amount for which goods are either bought by or sold by a dealer whether for cash or for deferred payment or other valuable consideration . ... . .. ." Sales tax is levied on the dealers on their total turnover for each year of account at t