SATYANARAYANA RAO, J.

These two petitions relate to the same assessee. T.R.C. No. 2112 of 1952 relates to the assessment year 1948-49 while T.R.C. No. 2111 of 1952 relates to the assessment year 1949-50. The assessee is the Indian Coffee Board, Batlagundu. It was assessed to sales tax on a turnover of Rs. 1, 97, 30, 968-6-3 during the assessment year 1948-49 and on a turnover of Rs. 3, 89, 275-2-8 during the assessment year 1949-50. The only question which was raised and argued on behalf of the assessee in these two petitions was whether the assessee, the Indian Coffee Board, which derives its existence from the Coffee Market Expansion Act (VII of 1942) is a dealer within the meaning of Section 2(b) of the Madras General Sales Tax Act, 1939. The definition as given in the Act is :-

"'Dealer' means any person who carries on the business of buying or selling goods."

There is an explanation to the definition which states :-

"A co-operative society, a club, a firm, or any association which sells goods to its members is a dealer within the meaning of this clause."

To solve the problem raised it is necessary to refer to the provisions of the Coffee Market Expansion Act, 1942, unde