JUDGMENT

Kapadia, J.-Leave granted.

2. These civil appeals by special leave involve common question of law as to whether the State has power and competency to levy tax on paddy, purchased by the miller for sale of rice to the exporter, in view of section 5(3) read with section 15(ca) of Central Sales Tax Act, 1956 (hereinafter referred to as "the 1956 Act").

3. For the sake of convenience, we may refer to the facts of Civil Appeal Nos. 3674-3710 of 2002. Appellant is the miller. It produces paddy, processes it and sells rice to the exporter who exports it out of India. In the assessment proceedings, the appellant claimed that in view of Article 286 of the Constitution and section 5(3) and 15(ca) of the 1956 Act, the State was not competent to levy purchase tax on the paddy purchased by it for sale of rice to the exporter. The appellant filed sales tax returns for four assessment years 1996-1997 to 1999-2000 in accordance with section 25 of the Haryana General Sales Tax Act, 1973 (hereinafter referred to as "the 1973 Act"). On August 16, 1999, the sales tax tribunal accepted a similar claim of dealer M/s Veerumal Monga & Sons vide sales tax appeal No. 698 of 1998-99. Later in review by