Judgment

PATHAK, CJI.:- The petitioners manufacture electronic goods, including television sets. television cameras and television monitors. The factories are located at Delhi, and the goods are sold through sales organisations spread all over India, including the State of Gujarat.

2. S. 7 of the Gujarat Sales Tax Act, 1969 provides for the levy of sales tax on the turnover of sales of goods specified in Part A, Sch. II appended to the Act. Entry 80A(a) of Part A of Sch. II specifies the rate of tax applicable to the turnover of television sets. The rate was 15% originally up to 1981, The Entry applied to all television sets, whether manufactured and sold within the State of Gujarat or imported from outside the State. No distinction was made between the goods on the basis of the place of manufacture.

3. Sub-s. (2) of S.49 of the Act empowers the State Government to exempt, in the public interest, any specified class of sales from payment of the whole or any part of the tax payable under the Act. In 1981, while the rate for electronic goods entering the State for sale therein was maintained at 15%, the rate in respect if locally manufactured goods was reduced to 6% by Notification No.