VEERASWAMI, C.J.

These petitions filed by the National Chamber of Commerce, Madras, impugned the validity of assessments of sales tax on transactions involving import by it of art silk, dyes and chemicals and distribution thereof to its members who held actual user's licence. The petitioner has registered itself as a dealer and would appear to have even collected sales tax from its members to whom distribution was made of the imported stuff. The department assessed the transactions not only on the basis of those facts but also on the view that the explanation to the definition of "dealer" would apply, that is to say, a society or an association which, whether or not in the course of business, buys, sells, supplies or distributes goods from or to its members for cash, or for deferred payment, or for commission, remuneration or other valuable consideration, shall be deemed to be a dealer for the purposes of the Act. Reliance was also apparently placed on explanation (1) to the definition of "sale". According to the explanation the transfer of the property involved by supply or distribution of goods by a society shall be deemed to be a sale for the purposes of the Act.

There