RAJAGOPALAN, J.

This petition is by the assessee to revise the order of the Appellate Tribunal with reference to the assessment under the General Sales Tax Act for the assessment year 1949-50. It was common ground that the assessee grew sugarcane in his fields, converted the juice into jaggery and sold the jaggery for Rs. 20, 536-14-0 during the course of the year; and it was on that turnover on the sales of jaggery effected during the course of the year that he was assessed. The Appellate Tribunal rejected the contentions of the assessee (1) that he was not a dealer as defined by the Act and (2) that the sales of jaggery would be sales of agricultural produce within the meaning of the definition of "turnover" in Section 2(i) of the Act.

"Dealer" is defined as a "person who carries on the business of selling goods." What the assessee did in this particular instance was to organise the sale of jaggery, first by converting agricultural produce into the marketable commodity of jaggery, and then by selling the jaggery from time to time. In the previous years he sold the sugarcane itself which shows that there was market for sugarcane. We are unable to see any force in the con