SHRIPAT RAO PALNITKAR, J.

I have had the advantage of perusing the two divergent judgments prepared by my learned colleagues, Mohd. Ahmed Ansari and Srinivasachari, JJ. After carefully considering the facts of the case, I agree with the conclusions arrived at by my learned brother Srinivasachari, J., that the petition should be dismissed.

I need only refer briefly to the facts of the case. Detailed facts are given in the two differing judgments, and I need not repeat them at length.

The petitioner is a member of the Warangal Sabha Oil Mill-Owners' Association, who, in course of his business, purchased various quantities of groundnuts from several persons, including producers or agriculturists, who had grown groundnuts. It is abundantly clear that the purpose of buying the groundnuts was to extract oil therefrom. The petitioner alleged that he and the other members of the Oil Mill-Owners' Association, being registered dealers under the Hyderabad General sales Tax Act (which Act will henceforward be called the Act in this judgment), were and are being asked to pay the sales tax on their purchase turnover; that the said Association and its members, including the petitioner, w