VEERASWAMI, J.

The Commercial Tax Officer, Coimbatore (North), served upon the petitioner a notice dated 29th September, 1959, intimating him that with the coming into force of the Madras General Sales Tax Act, 1959, on and from 1st April, 1959, the sales of arecanuts by him could no longer be classified as agricultural produce within the definition of turnover in section 2(r) and explanation (1) and that he was liable to pay tax on his sales of arecanut from that date. The officer, therefore, called upon him to file returns in the prescribed form showing his estimated total and taxable turnover for the year 1959-60, which should be based on the turnover of actual sales of arecanut the petitioner had made during 1958-59. The notice wound up by a warning that in default of submission of return as required, his turnover would be estimated to the best of judgment at Rs. 6 lakhs and he would be provisionally assessed for the year 1959-60. Certain correspondence followed between the petitioner and the Commercial Tax Officer, in which the petitioner maintained that he being a producer of arecanuts which constituted an agricultural produce, sales thereof were not taxable, while