Judgment

RANGANATH MISRA, J.:- The short point raised in these appeals by special leave directed against the judgment of the Gauhati High Court is as to whether the assessee appellant is liable to be taxed under the Assam Finance (Sales Tax) Act, 1956 (State Act for short), and the Central Sales Tax Act, 1956 (Central Act). When assessments were completed under the two Acts in spite of the resistance of the assessee which took the stand that it was not a dealer and, therefore, was not liable to tax, writ petitions were filed before the High Court challenging the demands by contending that the appellant was not a dealer and the certificate of registration issued to it without any application on its behalf should be cancelled and the demands should be quashed. The appellant contended that the Central Government in the Ministry of Health, Family Planning and Urban Development had set up a Medical Store Depot at Gauhati for the purpose of procuring and supplying medical stores to the Government institutions, both Central and State, as also the Railway establishments located in Assam, North Eastern Frontier Areas, Nagaland, Manipur, Tripura and other neighbouring places on payment. The D