K. M. NATARAJAN, J.

These three revisions, arising out of a common order, are filed by the assessee, namely, Perambalur Sugar Mills Ltd. represented by its Chairman and Managing Director, Madras, challenging the order passed by the Tamil Nadu Sales Tax Appellate Tribunal (Additional Bench), Madurai, in M.T.A. Nos. 48, 671 and 49 of 1985, respectively. The assessment order is in respect of three assessment years 1980-81, 1981-82 and 1982-83. The value of the disputed turnover is Rs. 7, 07, 878, Rs. 14, 48, 903 and Rs. 15, 55, 878, respectively for the three assessment years.

The short facts which are necessary for the disposal of these revisions are as follows : The assessee contended that the transport charges paid to the third-party lorry owners for transporting sugarcane from the fields of sugarcane growers to the assessee's factory premises are eligible for exemption of tax under rule 6(c) of the Tamil Nadu General Sales Tax Rules, 1959, and the same should not be treated as purchase turnover for the purpose of assessment under the Tamil Nadu General Sales Tax Act, relying on the observations made in the judgment of the Madras High Court in the case in State of Tamil N