Judgement

SIKRI, J.; These two appeals by special leave are directed against the judgment of the Madras High Court in Tax Cases Nos. 100, 219, 220 and 225 (sic) of 1962, and involve the interpretation of S. 5 (2) of the Central Sales Tax Act (LXXIV of 1956) - hereinafter referred to as the Act. The relevant facts are these. The appellant K. G. Khosla and Co., hereinafter referred to as the assessee entered into a contract with the Director-General of Supplies and Disposal, New Delhi, for the supply of axle-box bodies. According to the contract the goods were to be manufactured in Belgium, and the D. G. I. S. D., London, or his representative, was to inspect the goods at the works of the manufactures. He was to issue an inspection certificate. Another inspection by the Deputy Director of Inspections. Ministry of W. H. and S. Madras, was provided for in the contract. It was his duty to issue inspection notes on Form No. WSB. 65 on receipt of a copy of the Inspection Certificate from the D. G. I. S. D., London and after verification and visual inspection The goods were to be manufactured according to specifications by M/s. La Brugeoies, ET, Nivelles, Belgium. The assessee was entitled