Case: Deputy Commissioner of Agricultural Income Tax and Sales Tax, South Zone, Quilon Vs. Greenham Estate Private Limited

The respondents are engaged in the business of growing rubber trees. They tap rubber trees, collect latex, convert the latex so collected into sheets and transport them to their customers who reside out of the State of Kerala pursuant to contracts of sale. The transactions are transactions of sale governed by the Central Sales Tax Act, 1956 (74 of 1956). That Act enacts by section 2(b) that a dealer means "any person who carries on the business of buying and selling go

Reasoning:
That was expressly so decided in Travancore Rubber and Tea Co.s case ([1967] 20 S.T.C. 520.). The court in that case held that a person who carries on the business of growing rubber trees, collecting latex and converting it into sheets for the purpose of marketing was not a dealer within the meaning of the Central Sales Tax Act even though he sold the rubber sheets.