Judgement

SARKARIA J. : These appeals by the State of Tamil Nadu on a certificate granted by the High Court under Article 133 (1) (c) of the Constitution raise a question as to the interpretation and scope of Section 7-A of the Madras General Sales Tax Act, 1959 (hereinafter called, the Madras Act).

2. All the respondents are dealers against whom either pre-assessment proceedings have been initiated or assessments have been made under Section 7-A of the Act on the purchase turnover of certain goods.

3. The assessee-respondents in Civil Appeals Nos. 1040. 1041, 1042 and 1044 of 1973 are said to have purchased arecanuts from agriculturists, and thereafter transported those goods outside the State for sale on consignment basis,

4. The twenty assessees in Civil Appeals Nos. 1046-48, 1054-1057, 1059-1060, 1061 to 1066, 1068 to 1072 of 1973 are alleged to have purchased Gingelly seeds from agriculturists. Gingelly seeds so purchased were crushed into oil by them.

5. The four respondents in Civil Appeals Nos. 1045, 1050, 1058 and 1067 of 1973 are alleged to have purchased butter from house-holders and then converted it into Ghee.

6. The three assessees in Civil Appeals Nos. 1051, 1052 and 1053