1. The tax revision cases raise a common question of law, viz., when timber logs are converted into sizes, planks and scantlings, are the logs consumed in the manufacture of other goods so as to attract tax liability under S.SA (1) (a) of the Kerala General Sales Tax Act, 1963.

2 S.5A(1)(a) reads:-

"5A. (1) Levy of purchase tax. Every dealer who in in the course of his business purchases from a registered dealer or from any other person any goods, the sale or purchase of which is liable to tax under this Act, in circumstances in which no tax is payable under S.5, and either

(a) consumes such goods in the manufacture of other goods for sale or otherwise; or

(b) xx xx

(c) xx xx

shall, whatever be the quantum of the turnover relating to such purpose for a year, pay tax on the taxable turnover relating to such purchase for that year at the rates mentioned in S.Y.

2. That timber logs purchased by the assessees are subjected to some treatment, labour and manipulation, namely, sawing and very often, some processing prior to that, and that as a result thereof some change or transformation occurs to those logs admit of no doubt. But are the timber logs 'consumed in the manufacture of o