JUDGMENT

A. C. GUPTA, J. :— The appellant in Civil Appeal No. 928 of 1975, M/s. Karam Chand Thapar and Brothers, is a limited company incorporated under the Companies Act, (referred to hereinafter as the Company), and the six branches of the Company at Allahabad, Moradabad, Kanpur, Varanasi, Gorakhpur and Lucknow are the appellants in Civil Appeal No. 929 of 1975. The Company carries on business as coal agents and is registered under the Uttar Pradesh Sales Tax Act, 1948 and the Central Sales Tax Act, 1956 with the Sales Tax Officer at Moradabad in Utter Pradesh. We shall refer to these two statutes as the U. P. Act and the Central Act for the sake of brevity. The Company used to arrange supply of coal from colleries situate in West Bengal and Bihar to consumers in Uttar Pradesh. The collieries used to sent the coal by rail and the railway receipts wer prepared either in the name of the Company or in the name of the consumer in Utter Pradesh on whose behalf the order for supply of coal was placed. The collieries sent the bills and invoices in respect of the coal despatched to Uttar Pradesh to the Companys head office in Calcutta; the Company forwarded the railway receipts to the co