( 1 ) THE question which arises for considera,tion in these appeals by certificate is whether the respondents (hereinafter referred to as 'the assessees') are liable to pay purchase tax under S. 6 (i) of the Karnataka Sales Tax Act, 1957 (hereinafter referred to as the act') on the turnover consisting of the price paid by them for purchasing paddy for the purpose of converting it into rice for sale, in their respective rice mills.

( 2 ) THE assessees are owners of rice mills in the State of Karnataka and are registered dealers under the Act. In the course of their business, they purchase paddy and after milling paddy sell the resultant rice. During the assessment years, the assessees purchased paddy from agriculturists who were not liable to pay sales tax. The assessing authority under the Act levied on the asses- see in each of these cases purchase tax on the purchase turnover of paddy under S. 6 (i) of the Act. The appeals filed by the assessees against the said assessments were dismissed by the appellate authority. The Karna,taka sales Tax Appellate Tribunal allowed the appeals filed by the assessees against the orders of the appellate authority except the one