JUDGMENT

FAZL ALI, J.:—This is an appeal by special leave against the judgment and order of the Madhya Pradesh High Court dated April 23, 1974 dismissing the writ petition filed by the appellant before the High Court for quashing the orders of the Assessing Authorities imposing tax under the Central Sales Tax Act, 1956 on the basis of a number of sales made by the appellant Company in pursuance of multifarious contracts of sale. The appellant Company was formed in pursuance of an agreement dated June 8, 1962 between the President of India and the Central Provinces Manganese Ore Co. Limited. Before this agreement the said Company which will be hereafter referred to as the C. P. M. O. C. was a private company incorporated in the United Kingdom and carried on the business of extracting manganese ore from several mines in the erstwhile States of C. P. and Berar and Bombay. By virtue of the agreement referred to above a new Company was formed under which the Government of India, the Government of Maharashtra and the Government of Madhya Pradesh held shares in the ratio of 17% each whereas the original Company C. P. M. O. C. retained shares to the extent of 49 per cent. Thus the positi