( 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

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