SATYANARAYANA RAO, J.

All these four second appeals by the Provincial Government of Madras raise interesting and difficult questions of law under the Madras General Sales Tax Act, 1939, (Madras Act IX of 1939), referred to in the judgment as "the Act"). The appellants were unsuccessful in both the Courts and hence these second appeals.

The four suits out of which these second appeals arise were instituted in the District Munsif's Court of Bellary by different plaintiffs against the Provincial Government for a declaration that the assessment of sales tax imposed upon them was illegal and void. As the suits raised common questions of law and similar questions of fact, by consent of parties they were tried together and disposed of by a common judgment both by the District Munsif and by the learned District Judge.

The plaintiffs are commission agents who carry on trade at a place called Adoni in Bellary District. Besides the commission business, they also carry on independent business of their own. Under Section 8 of the Act they were granted licences permitting them to carry on commission business which is styled Dalali Agency in the judgment. Under the terms of the licence t