SRINIVASAN, J.

The petitioners in these cases are dealers in groundnut oil. They sold groundnut oil to Hindustan Lever Limited, which in its turn utilised the oil for the manufacture of vanaspati. The exact quantum of the turnover of such sales is not of importance, for only a question of interpretation of a provision of the Sales Tax Act is called for and that question arises in the following manner : Under section 3 of the Madras General Sales Tax Act, 1959, every dealer whose total turnover for a year is not less than Rs. 10, 000, shall pay a tax for each year at the rate of 2 per cent. on his taxable turnover. It would be sufficient to state the general liability of the dealer in such broad terms. The First Schedule lists out a number of goods, and sub-section (2) of section 3 states that in the case of goods mentioned in the First Schedule, the tax shall be payable at the rate and only at the point specified therein on the turnover relating to such goods, whatever may be the quantum of turnover in that year. This is in the nature of an exception to section 3(1). Sub-section (3) states :

"Notwithstanding anything contained in sub-section (1) or sub-section (2), the ta