JUDGMENT

Sen, J.-The appellant, M/s. Anand Commercial Agencies, is a partnership firm. It is regularly assessed under the Andhra Pradesh General Sales Tax Act. The dispute in this case arose in the course of assessment for the assessment year 1977-88. Under Entry 24(b) of the First Schedule to the Act, tax is payable on groundnut oil at the rate of 2-1/2 paise per rupee of the sale price. Under Entry 24(a), tax is payable on groundnut oil or refined oil obtained from groundnut which has not borne any tax under the A.P. Act at the rate of 6-1/2 paise per rupee of the sale price. The assessee at the relevant period had a total turnover of Rs. 31,35,000/- out of which Rs. 14,76,000/- was on account of sale of groundnut oil and refined oil obtained from groundnut which had not borne tax under the A.P. Act because the oil was imported into Andhra Pradesh from the State of Karnataka.

2. The case of the appellant is that the oil had been extracted out of groundnuts which had borne tax under the Karnataka Sales Tax Act. The levy of tax on the oil imported from Karnataka into Andhra Pradesh at a rate higher than the rate at which the oil manufactured in Andhra Pradesh is taxed is discriminato