The judgment of the Court was delivered by

JANARTHANAM, J. - Chengalvarayan Go-operative Sugar Mills Limited, Periyasevalai-607 209 (for short, "CCSM Ltd.") is the petitioner, while the State of Tamil Nadu represented by the Deputy Commercial Tax Officer, Full Additional Charge, Thirukoilur is the respondent in all these present tax cases (revisions) - Tax Case Nos. 474 to 478 of 1993. All these tax cases are relatable to the assessment years 1985-86, 1986-87, 1987-88, 1988-89 and 1989-90.

2. Certain statutory provisions governing the procurement of sugarcane, a raw material for the manufacture of sugar and matters allied thereto, besides the factual matrix - we rather feel - may be related here, in order to understand and have a fine grasp, with ease and grace, of the implications of the knotty legal questions - which we may pen down a little later - confronting us for a solution.

3. The Madras Sugar Factories (Control) Act, 1949 (for short, "the MSFC Act") provides for definition of "planting season", by section 2(gg) and "crushing season" by section 2(b).

(a) "Planting season", according to section 2(gg) means, in relation to any local area, such period or periods as ma