S.S.Dulat, J.

1. These two petitions under Article 226 of the Constitution involve the same question of law. The controversy is not about the law which is applicable-not even very much about the meaning of that law-but mostly about the manner of its application in two cases. Each of the petitioners is a company registered as a dealer under the Punjab General Sales Tax Act, 1948 . They both deal in cotton, purchase large quantities of unginned cotton, gin it and then dispose of the proceeds consisting of ginned cotton and cotton-seeds. The Punjab General Sales Tax Act imposes a purchase tax on goods specified in Schedule C of the Act and that Schedule mentions cotton, both ginned and unginned, and also oil-seeds which naturally include cotton-seeds. The Act provides-and quite properly if I may say so-that in respect of goods subjected to the purchase tax no sales tax will be levied. Further, the Act provides that if goods subjected to the purchase tax are sold to a registered dealer within a certain time or exported out of India or sold in the course of inter-State trade then the purchase price of the goods sold will be excluded from the taxable turnover or, to quote the wor