Rajagopalan, J.- The assessee was a registered dealer in ground-nuts, and he was also a registered manufacturer of ground-nut oil. The assessment with which we are concerned was for the assessment year 1950-51. The assessee objected to the inclusion in his taxable turnover of the purchase price of ground-nuts on the ground, that he was not liable to pay any sales tax under the Act until that ground-nut had been sold. That contention was repelled by the Tribunal. “Dealer” is no doubt defined by section 2 of the Act as “any person who carries on the business of buying or selling goods.” We are unable to accept the interpretation placed upon that section by the learned counsel for the petitioner, which would really convert the definition into something like this: "Dealer" means a person who carries on the business of buying and selling the very goods he bought.” We see no basis in the scheme of the Act or in the wording of the section for such an interpretation. Under rule 4(2) of the Madras General Sales Tax Turnover and Assessment Rules, dealings in groundnut are taxable at the purchase point. It was on the purchase point that the assessee was taxed. When exactly he sold the ground-nut, he had purchased or when exactly he converted that ground-nut into oil did not matter, so long as the condition required by rule 4(2) was satisfied, that the ground-nut was purchased by the dealer, i.e., assessee in the course of his business. As we have pointed out before, his business was that of a dealer in ground-nut and a manufacturer of ground-nut oil. It was in the course of that business that he bought the ground-nut and he became liable to tax. But it should also be remembered that what is taxable under section 3 is the turnover for the year. There was, therefore, no need for further investigation, whether the ground-nut so bought during the assessment year, on the basis of which the taxable turnover was fixed, was proved to have been sold, either wholly or in part. This question was also discussed in State of Madras v. Messrs. Eastern Supplies Ltd.1, when the scope of rule 4(2) and the scope of the charging section 3 were discussed; and there is no need to set outthose reasons over again now. This question was also discussed in State of Madras v. Messrs. Eastern Supplies Ltd.1, when the scope of rule 4(2) and the scope of the charging section 3 were discussed; and there is no need to set outthose reasons over again now. Following our previous decision, we hold there is no substance in the contention of the assessee, that rule 4(2) of the Sales Tax Turnover and Assessment Rules did not authorise the imposition of a sales tax on the turnover on the purchase price until there was proof that what had been bought was also sold. The next contention of the assessee was that, what rule 4(2) referred to was ground-nut and that it did not include ground-nut kernel. We are unable to accept this contention either. That was also rejected by the Tribunal. Ground-nut kernel is certainly part of ground-nut, and whether the ground-nut bought by the dealer was sold as ground-nut or was sold as ground-nut kernel or was subsequently converted into oil and sold as oil, what was taxable was the purchase. We agree with the Tribunal in holding that the expression ground-nut, even as the expression in clause 2(b) “Cashew” included the kernel in this case, the ground-nut kernel: The third point urged by the assessee was that in allowing the deduction under yule 18 of the Madras General Sales Tax Act Turnover and Assessment Rules read with rule 5 (i)(k), the assessee was entitled also to deduct the purchase price of ground-nut or ground-nut kernel when the purchases were made outside the taxable territory. We agree with the Tribunal in rejecting this contention also. The scheme of the taxation is not to provide for any special concession for the manufacture and sale of the ground-nut oil as such. The scheme, as we understand it, is that if a registered manufacturer of oil purchases ground-nut and pays tax under rule 4(2) on the purchase of that ground-nut, if he subsequently converts that ground-nut into oil and sells the oil, he would normally be liable to further sales tax on the sales turnover of that oil but for rule 18(2). Therefore, if he has already paid the tax on the purchase of the ground-nut which was subsequently converted into oil, he is given a deduction under rule 18(2) read with rule 5(1)(k) of the Turnover and Assessment Rules. Therefore, if he has already paid the tax on the purchase of the ground-nut which was subsequently converted into oil, he is given a deduction under rule 18(2) read with rule 5(1)(k) of the Turnover and Assessment Rules. We have already discussed the question in other cases and held that where oil is sold without liability to sales tax no question of deduction arises. The converse of it is what we have to consider in this case. Such deduction is allowed only where the purchase has already been made subject to tax under the Sales Tax Act. If the purchases were made outside the State of Madras, these purchases would not come within the scope of rule 4(2); and if ground-nut oil is extracted from ground-nut on the purchase of which no tax was paid, the sales turnover of such oil would be liable to tax under the scheme of the Sales Tax Act, and rule 18(2) would not apply to the turnover of the oil so extracted from ground-nut on the purchase of which no tax was paid. The last point urged was based upon Article 286(3) of the Constitution which runs thus: “No law made by the Legislature of a State imposing or authorising the imposition of a tax on the sale or purchase of any such goods as have been declared by Parliament by law to be essential for the life of the community shall have effect unless it has been reserved for the consideration of the President and has received his assent.” The learned counsel for the petitioner contended that ground-nut was declared by Parliament in 1952 to be-an essential commodity, and that therefore, the levy of any tax even on the purchase of ground-nut was opposed to Article 286 (3). Article 286(3) would apply to any law made by a Legislature of a State subsequent to the date on which the Constitution came into force. Even apart from that, the ban of Article 286(3) will fall only after Parliament declares by law any goods as essential for the life of the community. We are concerned with the assessment year 1950-51. During that period, there was no declaration by Parliament by law that ground-nut was an essential commodity, essential for the life of the community. The contention from either point of view has to be rejected. We are concerned with the assessment year 1950-51. During that period, there was no declaration by Parliament by law that ground-nut was an essential commodity, essential for the life of the community. The contention from either point of view has to be rejected. The petition is dismissed with costs which we fix at Rs.250. K.S. ------ Petition dismissed.