SEETHARAM REDDY, J.

( 1 ) THE petitioners, 39 in number, are dealers in milk, mining-materials, butter, gold, silver and so forth. They assail the validity of the amended section 6-A of the Andhra Pradesh General Sales Tax Act (hereinafter referred to as "the Act") which seeks to impose tax on purchase point, hitherto not exigible on various grounds.

( 2 ) THE petitioners, admittedly dealers, purchase goods such as milk, butter and so forth and then covert into a product like Horlicks and ghee and dispose of the same thereafter. Admittedly the by-product later, on its disposal, is subjected to tax. By Amendment Act No. 49 of 1976 dated 19/08/1976, to be effective from 1/09/1976, the new section 6-A was brought in by which any dealer, who purchases goods either from a registered dealer or from a person other than a registered dealer, will pay tax on the turnover, though the tax hitherto was not payable under section 5 or under section 6 of the Act.

( 3 ) IT is common ground that in all these cases we are solely concerned with the adjudication on questions of law, and therefore, we confine ourselves with the same without dwelling on the factual side of each petition.

( 4 ) THE conten

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