Judgment

HEGDE, J.

( 1 ) THESE are appeals by certificate. They raise common questions of law for decision, and they are directed against a common judgment of the Allahabad High Court.

( 2 ) THE facts of the case lie within a narrow compass. The appellants are dealers in foodgrains including cereals and pulses especially split or processed foodgrains and dal. The dispute in this case centres round the question whether the Government is competent to levy sales tax on the purchases made by the appellants of split or processed foodgrains and dal under the provisions of the United Provisions Sales Tax Act, 1948 as amended by the Uttar Pradesh Sales Tax Act (Amendment and Validation Act, 1970 (which will hereinafter be referred to as the Act ).

( 3 ) UNDER the Sales Tax Act as it originally stood (which will hereinafter be referred to as the principal Act), the purchases of split or processed foodgrains and dal by dealers were sought, to be brought to tax under Section 3-D of the principal Act read with the notification issued. The validity of the levy was challenged by Tilock Chand Prasan Kumar, the appellant in Civil Appeal No. 1625 of 1971 in respect of the assessment made on him for