Judgment

SHAH, J. : This is a group of appeals filed by the State of Madras against orders passed by the High Court of Judicature at Madras which raises the following common question as to applicability of concessional rate of sales tax to transactions of inter State sale and taxable under the Central Sales Tax Act, 1956 :

"When a purchasing dealer in one State furnishes in Form C prescribed under the Central Sales Tax (Registration and Turnover) Rules, 1957, to the selling dealer in another State a declaration, certifying that the goods ordered, purchased or supplied are covered by the certificate of registration obtained by the purchasing dealer in Form B prescribed under R. 5 (1) of the Central Sales Tax (Registration and Turnover) Rules, 1957 , and that the goods are intended for resale, or for use in manufacture of goods for sale or for use in the execution of contracts, or for packing of goods for resale, and that declaration produced by the selling dealer, is it open to the Sales Tax authority under the Central Sales Tax Act to deny to the selling dealer the benefit of concessional rates under S. 8. (1) of the Central Sales Tax Act, 1956, on the view that the certificate i