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3. The necessary and material facts are in a short compass and may briefly be stated: Respondent Haji Ismail Noor Mohammad & Co. a registered firm of partners was a "Dealer" registered under the Act. It, inter-alia, carried on the business of manufacture of oils from groundnuts and other oil seeds. The oil so manufactured was sold by the Dealer both intra-state; inter-state and by way of export.

Under Section 3-D of the Act, a dealer is liable to purchase-tax on oil seeds at 3% ad-valorem on the turnover of the purchases made by the dealer from the cultivators or other unregistered dealers. Section 4-B of the Act, however, contemplates special reliefs to certain manufactures of notified goods, the relief being in the form of concessional rate of purchase tax or exemption there from, as the case may be, as notified by the State-Government if the "dealer holds a recognition-certificate issued under sub-section (2) in respect thereof."