JUDGMENT

H. R. KHANNA, J. :—This is an appeal by special leave against the judgment of the Kerala High Court dismissing revision petition of the petitioner against the order in appeal of the Appellant Tribunal whereby the Tribunal refused to include certain items in the sales tax registration certificate of the appellant.

2. The appellant, Travancore Tea Estates Co., Ltd., is a company incorporated in England having its registered office in London. The appellant carries on the business of tea planting in India at Vandiperiyar in Peermade Taluk in Kerala State. Eight tea estates are owned by the appellant in Peermade Taluk. To manufacture tea grown in those estates, the appellant maintains separate tea factories in each of those estates. On an application may by the appellant for registration under the Central Sales Tax Act, 1956 (Act 74 of 1956) (hereinafter referred to as the Act), the sales tax authorities granted registration certificate to the appellant on January 9, 1963. Aggrieved by the non-inclusion of certain items of goods in the registration certificate, the appellant filed writ petition in the Kerala High Court. The High Court directed the Sales Tax Officer to decide t