Judgment

GROVER, J.:- These appeals have been brought by special leave against a common judgment of the Mysore High Court.

2. The facts are not in dispute. The assessee is a dealer in iron ore. It purchases iron ore from mine owners in Hospet and sells them to the State Trading Corporation for export to foreign countries. The assessee and the State Trading Corporation are registered as dealers under the Mysore Sales Tax Act, 1957, hereinafter called the "Act". According to the agreement between the parties ore was to be transported by rail from Hospet to Hubli and from there by road to Karwar port where it was loaded into ships for transportation to foreign countries. All expenses of transportation from Hospet to the point where the ore was loaded in ships were to be borne by the assessee. The documents relating to transport by rail such as way bills, Railway Receipts etc. were made out in the name of the State Trading Corporation. In these documents the ore was shown as consigned by the State Trading Corporation to itself. The railway wagons for transportation were also arranged by the State Trading Corporation but from Hubli to Karwar it was the assessee who engaged trucks for tran