Judgment :- 1. The only question in these revisions is whether shade tress out and sold as timber or firewood by owners of coffee and other plantations is exigible to tax under the Kerala General Sales Tax Act. 2. In Manager, Pulpally Devaswom v. State of Kerala (1977) 40 STC 350 this Court held that turnover in regard to such trees of spontaneous growth could not be taxed because: (i) to bring 'occasional transactions' within the meaning of S.2 (vii), they should be transactions of a business nature; and (ii) to bring them under S.2 (viii) (e), the sales should be of goods produced by the seller. The Sales Tax Appellate Tribunal has only followed the above view of this Court, and we are unable to hold that the orders under revision are erroneous. 3. Counsel for the Revenue contends that the decision in Pulpally Devaswom is opposed to the view taken earlier by this Court in the Kottumalai Tea Co. case (TRC. Nos. 64 & 65 of 1971) and in TRC. No. 34 of 1973. We cannot agree The question in the above cases was whether in view of the definitions in S.2(vii) and S.2(viii) (e) of the Kerala Act, the term "dealer" should be understood to denote only a person normally engaged in the business of selling and buying. And this Court held that even a person engaging in casual transactions could be regarded as a dealer in view of the wider language. The two questions specifically considered in Pulpally (40 STC. 350) and noticed in the preceding paragraph were not separately examined in those cases. 4. It is not disputed that at the material time, "occasional transactions of a business nature" alone were comprehended by the definition of 'casual trader' in S.2(vii). Therefore, the transaction had to be a business transaction i. e. "an adventure in the nature of trade or commerce", before the person responsible for it could be treated as a ‘casual trader', and consequently, a ‘dealer'. This view taken in the Pulpally case is in fact supported by the earlier decision of another bench in Dy. Commissioner v. Tirumbadi Rubber Co. (1975) 36 STC. 492. We are in respectful agreement with the above view, and we see nothing in T. R. C. Nos. 64 and 65 of 1971 or in T.R.C. No. 34 of 1973 contrary thereto. 5. Commissioner v. Tirumbadi Rubber Co. (1975) 36 STC. 492. We are in respectful agreement with the above view, and we see nothing in T. R. C. Nos. 64 and 65 of 1971 or in T.R.C. No. 34 of 1973 contrary thereto. 5. As for clause (e) of S.2 (viii), its language is clear on the point that only sales of goods produced by a seller (by way of manufacture, agriculture, horticulture or otherwise) could bring him within the meaning of "dealer" as defined in the sub-section. How can any one say that the mere cutting of a tree growing spontaneously would amount to production of goods by manufacture, agriculture or 'otherwise? Cutting is the final act in converting standing trees into 'goods'; and such a final act alone, without planting, nurturing and engaging in other activities antecedent thereto cannot be characterised as production of trees or timber by the cutter. The position may be different, for example, when a person plants teak or other trees and cuts them for being sold as poles or as timber, because the trees or timber could then be regarded as goods produced by him, but the same cannot be said about mere cutting of trees of spontaneous growth. Again, we are in respectful agreement with the approach made in Pulpally on this aspect. The distinction between trees duly planted and trees of spontaneous growth was not considered in T.R.C. Nos. 64 & 65 of 1971 or T.R.C. No. 34 of 1973; apparently, the point was not argued. A conflict requiring resolution by a larger bench is not involved on this point also. 6. To satisfy the element of 'sale' as understood in Explanation (I) to S.2(xxi) also, the timber must be produced by the seller. What has been said in connection with S.2(viii) (e) applies equally to the aforesaid Explanation. 7. All that is necessary to add is that we have not taken into account the amendments made to S.2 (vii) and S.2 (viii) (e) by Act 19/80 and Act 21/78 respectively, because the transactions involved in these revision were of earlier years. The revisions are accordingly dismissed, but without any order as to costs.