THANIKKACHALAM, J.

These tax case revisions relate to the three assessment years, viz., 1973-74, 1974-75 and 1975-76. There are four assesses in these five tax case revisions. The question arising in all these tax revision cases is common. Hence, they are taken up together for the sake of convenience. The common question that arises for consideration in all these tax revision cases is whether the goods have already suffered tax in the hands of the sellers.

2. Exemption was claimed by the assessees on the purchase turnovers involved in the revisions and the exemption sought for was granted on the ground that the purchases were second purchases in the hands of the assessees. Groundnut kernel is taxable at the point of the first purchase as single point goods. The assessing officer on verification has found that the exemption granted on the said purchase turnover on the said ground is not correct. According to the assessing officer, the Alangudi dealers are mere decorticators and they are not the dealers as defined under the relevant provisions of the Tamil Nadu General Sales Tax Act, 1959 (in short, "the Act"). In fact they are not the owners of the groundnut kernel purchas