( 1 ) IN these four connected appeals presented under section 24 (1) of the Karnataka Sales Tax Act (hereinafter referred to as "the Act") by the assessee, the following question of law arises for consideration : whether the assessee, who had purchased boulders under circumstances in which no tax was leviable at the purchase point and who converted them into jelly, in a process which is not a manufacturing process, is liable to tax under section 6 of the Karnataka Sales Tax Act ?

( 2 ) THE facts of the case are these : The assessee is a registered firm carrying on business in latrite and granite stones. During the relevant assessment years, the assessee purchased boulders from unregistered dealers, who are not liable to tax under section 5 of the Act. He produced jelly out of these boulders. For the assessment years 1970-71, 1972-73 and 1973-74, the turnovers of the assessee were as follows : 1970-71. . . Rs. 34,368. 00 1972-73. . . Rs. 71,725. 00 1973-74. . . Rs. 1,00,000. 00 in the first instance, the assessing authority did not levy tax on the said turnover under section 6 of the Act. Later in exercise of his power under section 12-A of the Act, the assessing auth