JUDGMENT

RANGANATHAN, J.:— The Civil Appeal and S. L.P. 12054/ 87 are by the State of Madhya Pradesh (M.P.). The respondents in these two matters and the petitioners in the other five Special Leave Petitions are certain concerns in M.P. assessable to sales tax (hereinafter compendiously referred to as the assessees). All these matters can be conveniently disposed of by a common judgment as they raise a common issue. ,

2. The assessees claim for exemption from sales tax for certain periods in question was accepted by the High Court in the case of G. S. Dhall & Flour Mills (reported in (1987) 20 STL 206) (Madh Pra) and, following it, in the case-of Mohd. Ismail (a case where the exemption sought for was originally granted but subsequently revoked). However, subsequently, a Full Bench of the High Court, in the case of Jagadamba Industries (reported in 1988 MPLJ 620) (FB), disapproved the view taken by the Division Bench in the G. S. Dhall & Flour Mills case and, following the Full Bench, the writ petitions filed by certain other assessees were dismissed by the High Court. The State is aggrieved by the judgment in the first two cases and the assessees by the High Courts decision in the