JUDGMENT Jagdish Sahai, J. - These three special appeals are directed against the judgment of Brij Lal Gupta, J. dated 3-11-1961, dismissing writ petition Nos. 55, 56 and 57 of 1961 in which the same question was raised. 2. Admittedly the appellants in the three cases before us grew sugarcane either on their land or on land in which they had an interest and from the sugarcane so produced prepared rab. The rab was sold in the market and the question is whether the amount received by way of the price of the rab could be included in the turnover of the three appellants, who admittedly are dealers within the meaning of the U.P. Sales Tax Act (hereinafter referred to as the Act). Sec. 2(i) of the Act, so far as relevant for our purposes, reads:- "(i) "turnover" means the aggregate amount for which goods are supplied or distributed by way of sale or bought or sold by a dealer, either directly or through another, on his account or on account of others, whether for cash or deferred payment or other valuable consideration: Provided that the proceeds of the sale by a person of agricultural or horticultural produce, grown by himself or grown on any land in which he has an interest whether as owner, usufructuary mortgagee, tenant or otherwise or poultry or dairy products from fowls or animals kept by him, shall be excluded from his turnover:" 3. Rab is not a direct produce from land but involves a manufacturing process. The sugar-cane is pressed and its juice extracted. This juice is boiled in five pans one after the other, every time some cleansing chemicals being used. Ultimately a semi-solid commodity is produced called rab. The question that requires consideration is whether it can be said that rab has been grown by the appellants or has been grown on any land in which the appellants have interest whether as owners or usufructuary mortgagees or tenants or otherwise. The Act does not define the word grown. In the Oxford English Dictionary amongst others the following meaning lias been given to the word grow:- "Develop or exist as living plan, sprout, spring up, be produced, come naturally into existence, arise." Normally, therefore, the word grown connotes some thing coming out of the soil, as for example, a tree, a sugarcane plant or paddy or wheat crop. 4. In the Oxford English Dictionary amongst others the following meaning lias been given to the word grow:- "Develop or exist as living plan, sprout, spring up, be produced, come naturally into existence, arise." Normally, therefore, the word grown connotes some thing coming out of the soil, as for example, a tree, a sugarcane plant or paddy or wheat crop. 4. The preamble of the Act reads:- "Whereas it is expedient to provide for the levy of a tax on the sale of goods in Uttar Pradesh:" 5. The word goods has been defined in Sec. 2(d) of the Act as follows:- " "goods" means every kind of movable property other than actionable claims, stocks, shares or securities, and includes growing crops, grass, trees and things attached to or fastened to anything permanently attached to the earth, but which, under the contract of sale, are agreed to be severed:" 6. Even sugarcane cut from the field would be "goods" within the meaning of this provision. That expression would include sugarcane juice and rab also. If rab is to be exempted from the purview of the turnover, it can only be on the ground that it has been grown by the appellants or has been grown on any land in which the appellants have an interest. The proviso would apply only under that condition. In our judgment however it cannot be said that rab is grown. As pointed out earlier, a manufacturing process is required before sugarcane can be converted into rab It is true that rab is a product of sugarcane, but it is so only in the sense in which cloth is the product of cotton. Most finished goods have their origin in agricultural produce, but that does not mean that those finished goods are agricultural produce. We are, therefore, of the opinion that rab was not grown by the appellants. 7. Learned counsel has placed reliance upon the analogy of wheat and rice and contended that even though the process of husking and winnowing is required before wheat and rice are produced nonetheless it is said that they have been grown on land. In our judgment this analogy is not correct. The process of husking and winnowing is an agricultural process and not a manufacturing one. 8. In our judgment this analogy is not correct. The process of husking and winnowing is an agricultural process and not a manufacturing one. 8. For the reasons mentioned above we are satisfied that the assessing authority was justified in including the price recovered by the appellants by the sale of rab in their turnover. We find support for our view from Bharat Engineering and Foundry Works v. The U.P. Government, 14 Sales Tax Cases 94 and K. P. Vaidyanatha Iyer v. The State of Madras, 1954 (V) Sales Tax Cases 94. 9. Brijlal Gupta, J. has placed reliance upon the State of Madras v. V. R. B. Gopalarathnam Gupta, 1954 (V) Sales Tax Cases 94. That case is distinguishable on the ground that the assessee in that case had neither grown the sugar cane which was converted into jaggery, nor was it produced on land in which he had any interest. Mr. Agarwala, who has appeared for the State, has placed reliance upon R. B. N. S. Borawake v. The State of Bombay, 11 STC 8. In that case the question requiring consideration was whether the price received by the sale of Gur produced by an agriculturist from sugarcane by himself could be treated to be turnover. The learned Judges observed as follows: "In the present case, with a view to prevent deterioration and for the purpose of facilitating transportation the assessee converted the sugarcane grown by him into gur and sold it. In our view, the taxing authorities and the Sales Tax Tribunal were in error in holding that the assessee is a dealer within the meaning of the definition in Sec. 2(6)." 10. The Bombay case was decided on the ground that the assesses was not a dealer. In our case the appellants are dealers. Consequently the Bombay case is also distinguishable. 11. For the reasons mentioned above we are satisfied that there are no merits in these special appeals. We, therefore, dismiss them with costs. Appeals dismissed.