RAJAGOPALAN, J.

These are petitions presented by the State under section 12B of the Madras General Sales Tax Act, against the decision of the Appellate Tribunal, which held that the arecanut sold by the assessees, all of whom belonged to the South Kanara district, was a horticultural produce within the meaning of section 2(i) of the Act.

In our judgment in T.R.C. No. 22 of 1955 (Since reported as The State of Madras v. R. Saravana Pillai, at page 541 supra) which has just been delivered, we pointed out the difference in the process adopted by the horticulturists of South Kanara district and those of Coimbatore district in preparing the arecanuts for sale. The process adopted by the horticulturists of South Kanara involves much less than that adopted by those of Coimbatore district. T.R.C. No. 22 of 1955 (Since reported as The State of Madras v. R. Saravana Pillai, at page 541 supra) was concerned with the processing to which the horticulturists of Coimbatore subjected the arecanuts. All that is done is South Kanara is to gather the arecanut, peel and dry the kernel before it is sold. That cannot result in what is sold ceasing to be horticultural produce within the meaning of section 2(i) of the Act. These petitions are dismissed.

Petitions dismissed.