K. SHIVASHANKAR BHAT, J. - Taxability under the provisions of the Karnataka Sales Tax Act, 1957 ("the Act", for short), is the question to be considered in all these petitions. The common question is whether the dealer who purchased timber in circumstances in which no sales tax was charged under section 5, is liable to pay tax on the said purchase price under section 6, because the timber purchased by him is cut or sawn by him, into sizes, logs, planks, rafters, etc., for purposes of sale.

The State contends that when timber is converted into logs, sizes, etc., a new product emerges and timber is consumed in the manufacture of the new products.

Section 6 to the extent relevant to consider the rival contentions read as follows :

"Section 6. Levy of purchase tar under certain circumstances. - Subject to the provisions of sub-section (5) of section 5, every dealer who in the course of his business purchases any taxable goods in circumstances in which no tax under section 5 is leviable on the sale price of such goods, and

(i) either consumes such goods in the manufacture of other goods for sale or otherwise or consumes otherwise, or disposes of such goods in any manner other t