JUDGMENT

B. P. JEEVAN REDDY, J.:- A common question arises in this batch of Appeals and Special Leave Petitions.

2. Leave granted in S.L.Ps.

3. In Commr. of Sales Tax, U.P. v.Hanuman Trading Co., (1979) 43 STC 408 a learned single Judge of the Allahabad High Court held that the purchases made by Commission Agents in U.P. on behalf of the principals outside the State, where the goods so purchased were despatched to such principals, were inter State purchases not exigible to tax under the U.P. Sales Tax Act, 1948. This decision was rendered on October 6, 1978. Civil Appeal No. 1809 of 1982 is preferred against the same. Following the said decision a large number of cases were disposed of by the Allahabad High Court which have given rise to the other Civil Appeals and the S.L.Ps. posted before us. Since the facts in all these appeals are stated to be identical, it is enough to refer to the facts in Civil Appeal No. 1809 of 1982. The facts as found recorded in the order of the High Court are to the following effect

The respondent-assessee, Hanuman Trading Company, is a registered dealer in Uttar Pradesh, dealing in foodgrains and oils among others. During the year in question, he purchased