JUDGMENT

SABYASACHI MUKHARJI, J.:—This is an appeal by special leave from the order dated 31st December, 1981 passed by the Sales Tax Tribunal, Orissa. The appellant who was the assessee under the Central Sales Tax Act, 1956 went up in appeal against the confirming orders of Assistant Commissioner in respect of the assessment years 1974-75, 1975-76 and 1976-77. The Sales Tax Officer, Koraput I Circle, Jeypore had made the orders under Rule 12(3) of the Central Sales Tax (Orissa) Rules, 1957 making demands of Rs. 1,21,38,586.00 for the year 1974-75, Rs. 1,29,64,637.00 for the year 1975-76 and Rs. 1,37,72,652.00 for the year 1976-77. The appellant is a dealer registered under Section 7(1) of the Central Sales Tax Act, 1956 under Koraput I Circle in the State of Orissa.

2. M/s. Hindustan Aeronautics Limited (hereinafter referred to as H. A. L.) of which appellant is a division was established on 1st October, 1964. The objective of formation of the H. A. L. was to carry on in India and elsewhere the business, inter alia, in aeroplanes including manufacture, assembling, buying and selling etc. of the same. In its division at Sunabeda, manufacture of MIG engines for MIG aircrafts required