Judgment

B.P. JEEVAN REDDY, J.- The petitioner is engaged in the manufacture inter alia of vanaspati. It has a plant at Ghaziabad in Uttar Pradesh.

2. With a view to ensure supply of vanaspati at a uniform rate throughout the country, the Government of India had evolved, in consultation with themanufacturers of vanaspati, a scheme known as "All India voluntary price control system", whereunder the manufacturers of vanaspati were obliged to sell vanaspati at a uniform price throughout the country. Oil is the main raw material for manufacturing vanaspati. Part of the oil so required was being imported through the agency of State Trading Corporation and sold to various manufacturers all over the country. Very often, the STC depot, nearest to the plant, was designated as the source from which the manufacturer was to draw the supply of imported oil. Since the manufacturers were obliged to sell vanaspati at a uniform price, the Government of India proposed to supply imported oil to all the manufacturers, wherever their plants are situated, at a uniform price. It is this aspect which gave rise to certain problems. The rates of sales tax on the sale of oil were not uniform throughout the co