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, under which the assessee Board was constituted. The Act was passed by the Indian Legislature on 2nd March, 1942, with a view to continue the provisions made under Ordinance XIII of 1940. The object of the Ordinance and the Act is to give assistance to the coffee industry by regulating the export and sale of coffee and by other means. This was done as declared by Section 2 of the Act with the object of the Central Government taking under its control the development of the coffee industry in the interests of the public. The control of marketing of farm produce for the economic benefit of the producers and to bring about collective marketing of the produce is a recognised feature of Governments of several countries, particularly, United States of America, Britain and Australia. The object is to prevent unhealthy competition between producers, to secure the best price for the produce in the local market, to conserve for local consumption as much produce as is needed and make available the surplus for export outside the States and also to foreign markets. The method usually adopted to achieve the object is to establish a marketing board with power to control the prices, to obtain possession of the produce and to pool it with a view to collective marketing. The legislation in this behalf is compendiously described as "pooling legislation" and is based on the fundamental idea that the collectivist economy is superior to individualistic economy. Thus there are different marketing boards for different kinds of produce, such as sugar, dairy produce, wheat, lime fruit, apples, pears and so on. The Indian Coffee Market Expansion Act was modelled somewhat on the lines which obtain in other countries and was intended to control the development of the coffee industry and to regulate the export and sale of coffee.Section 4 of the Act relates to the constitution of the Board, and representation of various interests in the production of coffee and its marketing is secured by this section. Under Section 5 the Board derives its incorporation and it is a body corporate having perpetual succession and a common seal with power to acquire and hold property, movable and immovable, and to enter into contracts; it could sue and be sued in the name of the Indian Coffee Board. Section 7 provides for the election of the chairman of the Board and for appointment of committees by the Board for such purposes as it may deem necessary for the efficient discharge of the functions under the Act. Section 8 provides for the appointment by the Central Government of a Chief Coffee Marketing Officer to exercise such powers and perform such duties under the directions of the Board as may be prescribed by the Central Government. Provision is also made for the appointment of Deputy Chief Coffee Mar