R. V. RAVEENDRAN, J. - These matters which involve a common question of law were listed for preliminary hearing and were finally heard by consent and are disposed of by this order. The common question that arises for consideration in these cases is whether the decision of the Supreme Court in Rajasthan Roller Flour Mills Association v. State of Rajasthan and State of Karnataka v. New Swastik Flour Mills [1993] 91 STC 408, is only prospective in its application and does not apply to transactions which had taken place prior to the date of the said decision, namely, September 1, 1993.

2. The necessary facts are :

Under section 6B of the Karnataka Sales Tax Act, 1957 ("the Act", for short), the total turnover of every dealer is liable to turnover tax. The proviso to the said section however excludes the turnover relating to several transactions listed therein from turnover tax. Item (ii) under the proviso excludes the turnover relating to sale or purchase of goods specified in the Fourth Schedule to the Act. Wheat is one of the items listed in the Fourth Schedule to the Act and therefore the turnover relating to wheat is exempted from turnover tax.

3. The Revenue considered "w