JUDGMENT

SABYASACHI MUKHARJI, J. :— We are concerned with Civil Appeal No. 642(NT) of 1974, Civil Appeals Nos. 1798-1800 of 1981 and the Writ Petition No. 196 of 1974 along with Special Leave Petitions Nos. 12943-44 of 1985. All these will have to be disposed of on the main question stated hereinafter and these raise a common question, facts in all these matters are more or less identical except that certain assumptions of facts have been made in Special Leave Petitions Nos. 12943-44 of 1985 because in these there were no investigation of facts by the revenue authorities.

2. The question involved in all these, is, whether the sales in question were within the State of Tamil Nadu and as such subject to tax under the Tamil Nadu General Sales Tax Act, 1959, hereinafter called the Act.

3. The dealers who are the petitioners in the writ petitions and are the appellants in the appeals and the petitioners in Special Leave Petitions are dealers in stores and were doing business as ship chandlers in the relevant years. The appellants / petitioners used to supply the goods imported as stores to foreign going vessels and other diplomatic personnel. The appellants/ petitioners imported these goo