( 1 ) THE sixteen sales-tax appeals are preferied by two dealers in desiccated coconut, aggrieved by the orders of the commissioner of Commercial Taxes made in exercise of his suo motu power of revision under S. 22-A of the Karnataka Sales-tax Act, (hereinafter referred to as 'the Act') setting aside the orders of the assessing authority for the relevant assessment years exempting their inter-state sale turnover cf desiccated coconut from sales-tax under the provisions of the Central. Sales- tax Act, 1956 (hereinafter referred to as 'the Central Act') and bringing the same to tax under S 8 of the Central act. Four revision petitions are preferred by the State aggrieved by the order of the Karnataka Appellate Tribunal upholding the claim of the respon lentfirm therein, which is also a dealer in desiccated coconut that inter-state sales of desiccated coconut are not exigible to tax under the Central Act. All these cases were heard together and are being disposed of by this common judgment as the same question of law arises for consideration in all these cases which is as follows: whether, the assessees, who had effected inter-state sales of desiccated coconut prepared by them out of the coconuts purchased by them within the State, were not liable to pay central Sales-tax on the sale turnover of such desiccated coconut, under s. 8 of the Central Act, on the ground that they had paid purchase tax on ihe coconuts as prescribed under S. 5 (4) read with entry 5 of the Fourth schedule of the Act and that desiccated coconut is the same as coconut, which is one of the 'declared goods' under S. 14 of the Central Act?

( 2 ) THE relevant statutory provisions on the interpretation of which these cases have, got to be decided and the facts of the case which have given rise to these appeals and revision petitions, are as follows: (1) S. 14 of the Central Act specifies certain goods, which are of special importance in inter-state trade and commerce defined, as 'declarea goods' under S. 2 (c) of the Central act. Declared goods specified in S. 14 of the Central Act includes coconut (i. e. , copra excluding tender coconut ). S. 15 of the Central Act provides that tax levied on sale or purchase of declared goods under State law shall not exceed 4% of the sale or purchase price and shall not be levied at more than one stage. Proviso to the said section provides that in cases where tax has been levied on declared goods under the State law and tax is paid on the same goods under the central Act, the tax levied under the state Law shall be reimbursed to the persons making such interstate sales. Under S. 8 (1) of the Central Act, every dealer who sells goods of the description referred to in sub-sec. (3) in the course of inter-state trade or commerce to the Government or to a registered dealer other than the government, is liable to pay tax under the Central Act at 4% of his turnover. Under Section 8 (2) (b) of the Central Act the tax payable by a dealer on his inter-state sale turnover of goods other than declared goods, and not falling under sub-section. (1) of S. 8 is 10%. (2) S. 5 (i) of the Act provides that every dealer shall pay for each year sales-tax at the rate of 4% on the Sale turnover of goods taxable under the act. Sub-sec. (4) of S. 5 is a special provision in respect of tax payable on goods declared to be of special importance in inter-state trade and commerce under S. 14 of the Central Act. According to this sub-section, tax is payable in respect of sale or purchase of goods which are specified in the Fourth schedule to the Act at the rate and only at the point specified in the corresponding entries of columns 3 and 4 of the said schedule. The rate specified for coconut is 3% and the point of levy is the earliest purchase in the state. (3) During the relevant assessment years, the Commercial tax Officer, in the proceedings relating to final assessments under the Central Act in the case of appellants considered the question as to whether

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