( 1 ) THE appellant is a partnership firm and a dealer registered under the provisions of the karnataka Sales Tax Act, 1957 (KST Act for short ). It is engaged in the process of extracting solvent oil from oil cake and soyabean seeds. In the course of its business activity, the appellant has purchased, both from registered and unregistered dealers sunflower oil cake, groundnut oil cake and soyabean seeds and consumed in the production of de-oiled sunflower oil cake, groundnut oil cake etc. , for sale. The purchases made from unregistered dealers, who are not liable to pay tax under the Act was to the tune of Rs. 81,39,300/- and Rs. 9,51,000/- respectively. The dealer had filed its annual returns in form-4 before the assessing authority claiming exemption on the purchase turnover of sunflower oil cake, groundnut oil cake and soyabean seeds from unregistered dealers, on the ground that the extraction of solvent oil out of oil cake and soyabean seeds does not amount to manufacture and the resultant product namely de-oiled sunflower oil cake and de-oiled groundnut oil cake are not new commercial commodities even in commercial circles nor in common parlance. The assessi