Ramachandran Nair, J.

The question arising in the connected Tax Revision Cases is whether petitioner is liable to pay sales tax at the point of first purchase on the collection and sale of cardamom for its members. We have heard senior counsel appearing for the petitioner and Government Pleader for respondents.

2. Petitioner is a society promoted mainly for marketing of agricultural produce of the members who are tribals in the Devikulam Taluk. Cardamom is one item produced by members and marketed by the society. In the course of assessment, the assessing officer treated the collection of cardamom by the petitioner from the members and sale of the same in auction by auctioneers as purchase and sale by the petitioner. Since cardamom is an item taxable at the point of first purchase in the State, petitioner was called upon to pay sales tax on this. In the first appeal filed by the petitioner, the appellate authority after verifying the records noticed that petitioner was engaged in marketing of produce of members. The nature of transaction as found by the appellate authority is collection of cardamom by the petitioner from the members against issue of receipt showing the q