K.S.Hegde, J.

(1) THE appellant, a Limited Company was a registered dealer under the central Sales Tax Act, 1956 (in brief the "Act). It was a manufacturer as well as a dealer in liquor. It was selling liquor to dealers in Pondicherry, Karakkal and Goa. For the year 1962-63, its total turnover of sales to places outside the State of Kerala, the State in which the appellants registered office is situate, was for Rs. 8,28,859.40 P. Out of this the value of the liquor sold to Goa after 21/01/1963 was Rs. 22,622.50 P. and the value of the liquor sold to Pondicherry including Karakkal after 16/08/1962 was Rs., 1,15,516.95 P. Pondicherry became Union Territory with effect from 16/08/1962 as a result of the Constitution (Fourteenth Amendment) Act, 1962 and Goa became Union territory with effect from 20/01/1961 as a result of Constitution (Twelfth Amendment) Act, 1962. The Act was brought into force in Goa with effect from 21/01/1963 and inpondicherry from 1/06/1963.

(2) S. 8 of the Act prescribes rates of tax on inter-State trade. The rate of tax on the sale of goods of the description mentioned in Ss. (3) of that S. to a registered dealer was I per cent of th