Judgment

VIVIAN BOSE, J. : This judgment will govern Civil Appeals Nos. 66 to 73 of 1957. They arise out of a certificate granted by the High Court of Mysore against a judgment of that Court delivered on 29-9-1955.

2. The appellant is the State of Mysore. The respondents are the Mysore and Minerva Mills respectively. The appellant sought to impose a sales tax on certain sales made by the two respondents between 31-3-1950, and 31-3-1951. The respondents contended, and still contend that these sales are not taxable because they were made in the course of export and so are exempt under Art. 286(1) (b) of the Constitution. The Sales Tax Officer rejected this contention and imposed the tax. Appeals were filed and failed, and also review petitions to the Commissioner of Sales Tax. The matter then came up to the High Court in the following ways.

3. The assessments were in respect of five quarters. The Commissioner made two references in respect of the first two quarters ending 31-3-1950, and 30-6-1950, respectively. These are Civil Petitions Nos. 110 of 1954 and 112 of 1954. The first related to the Minerva Mills and the second to the Mysore.

4. Writ petitions were filed in the Mysore High Co