RAMASWAMI, J.

Tax (Revision) Cases Nos. 411 and 412 of 1971 have been filed by the North Arcot District Co-operative Sugar Mills Ltd., now renamed as Ambur Co-operative Sugar Mills Ltd., Vadapudupet, North Arcot District, in respect of the assessment years 1967-68 and 1968-69. The turnover in both these assessments related to a portion of the amount paid by the assessee to the cane-growers in respect of the supply of sugarcane made by them. The broad pattern of the business as between the growers and the sugar mills as found by the Tribunal is as follows :

Before each crushing season, the mills enter into contracts with canegrowing ryots in the locality for delivering the sugarcane that will be cultivated and harvested in their fields. On the basis of this undertaking the mills also advance monies for the purchase of fertilizers and other cultivation activities, which amount is ultimately deducted from the price payable in respect of the sugarcane supplied by the ryots. The Sugarcane Inspector appointed by the mills inspects the sugarcane field in order to ensure their proper growth and quality. Under the Sugarcane Control Order, the Government of India fixes each year st