Judgment

GUPTA, J.:- In this petition under Art. 32 of the Constitution of India a dealer seeks relief from the same sales being assessed to sales tax both under the Central Sales Tax Act and the U. P. Sales Tax Act. The first petitioner Indian Oil Corporation Limited, IOC for short, are a Government company incorporated under the Companies Act, 1956 engaged inter alia in the manufacture and marketing of petroleum products. The second petitioner is the Managing Director and a shareholder of IOC. Union of India has been impleaded as the first respondent in the petition. The 2nd respondent is the Assistant, Superintendent of Commercial Taxes, Central Circle, Bihar. The 3rd and 4th respondents are respectively the State of Bihar and the State of U. P. The 5th respondent Indian Explosives Limited are a company having their registered office at Calcutta; they have a factory at Panki, Kanpur in Uttar Pradesh manufacturing urea fertilizers. IOC have a refinery at Barauni in the State of Bihar and also a depot at Panki, Kanpur. In 1966 IOC completed a pipeline from their refinery at Barauni in Bihar to Kanpur in U. P. through Patna in Bihar and Mughalsarali and Allahabad both in U. P. At th