(1) SLP(C) No.3091 of 1993 This special leave petition is filed against the judgment of the Full Bench of the High Court of Kerala in Hindustan Petroleum Corpn. Lid. (formerly Caltex Oil Refining (India) Ltd.) v. State of Kerala. The facts of the case briefly stated are that the petitioner Company which was at all material times dealing in petroleum products purchased petroleum products manufactured by another oil company known as Cochin Refineries Ltd. (for short CRL) which sold its products to Indian Oil Corporation (for short IOC) which in turn sold it to the petitioner. No sales tax was payable on these sales. The goods in question were transferred from bonded warehouse to bonded warehouse and no excise duty was actually paid. IOC while issuing regular bills to the petitioner indicated therein the value of goods sold only. The petitioner paid the excise duty on the said goods directly to the Government of India. The Sales Tax Tribunal (for short "the Tribunal") held that when the petitioner paid the excise duty leviable it merely discharged its contractual obligations arising out of the bond executed under the Central Excise Rules, 1944 (hereinafter called "the Rules")