1. The assessee is the same in all the three Tax Revision Cases; the question of law arising for our consideration is also the same. In T. R. C. Nos. 14 and 15 relating to the years 1967-68 and 1968-69 respectively, the assessee challenges a common order of the Kerala Sales-tax Appellate Tribunal. Following the said order, a separate order was passed by the Tribunal in respect of the year 1970-71 and this order is challenged in T.R.C. No. 13 of 1975. We propose to deal with these cases together and dispose of the same by a common judgment

2. The only point arising for our consideration is whether the petitioner-Devaswom is a dealer within the meaning of S.2 (viii) of the Kerala General Sales-tax Act, 1963 (hereinafter called the Act).

3. The Devaswom owned extensive private forests. On the strength of permits issued to it by the District Collector, Kozhikode, the Devaswom felled trees which had grown spontaneously in its forests. These trees were dressed by the Devaswom and sold as timber. The Sales tax Officer initiated assessment proceedings and issued notice under S.17 (3) of the Act, stating as follows:

"On enquiries conducted by me it is understood that you have been