Judgment

SUBBA RAO, CJI. : The decision on these appeals depends upon the interpretation of the relevant provisions of the Punjab General Sales Tax Act, 1948 (Punjab Act XLVI of 1948), as amended by Punjab Act of 1958, relating to three categories of goods, namely, oil-seeds, iron and cotton.

2. The facts may be briefly stated.

3. The assessees in Civil Appeals Nos. 526, 527 and 529 of 1964 carry on business at Moga in Punjab and each owns an oil mill. They purchase oil seeds and, after crushing the same in their oil mills, sell the oil and the residual oil-cake. They are registered dealers under the Act. The Amending Act imposed a purchase tax of 2 per cent on the purchase of oi1-seeds "for the use in the manufacture of goods for sale". This was in addition to the sales-tax leviable on the sales of oil and oil-cake. On June 23, 1959, the Excise and Taxation Officer, Ferozepore, the 3rd respondent in the said appeals issued notices to the 3 appellants-assessees to the effect that they did not submit their returns for the year ending 1958-.39 and failed to pay purchase-tax in respect thereof and asked them to show cause why they should not be prosecuted for the said default. The appell