( 1 ) THE writ petitioner is a Co-operative society registered under the Karnataka co-operative Societies Act, 1959 and is running a Sugar Factory at gouribidanur in Kolar Dist. Gouribidanur is approximately at a distance of 15 kilo metres away from the karnataka and Andhra Pradesh border in Karnataka. The Sugarcane growers of Andhra Pradesh approached the petitioner Society, according to the writ petitioner, with a request to purchase the sugarcane grown by them with a view to alleviate the suffering of the sugarcane growers from andhra Pradesh and the Board of management of the petitioner Society resolved to purchase the sugarcane grown by them. Pursuant to the said resolution of the Board, the Society purchased the sugarcane during the years 1973-74, 1974-75 and 1975-76. The petitioner has further submitted that at the time when the Board resolved to purchase the sugarcane from the growers in Andhra Pradesh, the purchase of sugarcane was exempted from tax under the General Sale tax Laws. The third respondent - the Asst. Director of Agriculture in the writ petition, however, issued a show cause notice demanding the tax at the rate of Ra. 10 per metric ton of sug