Judgment

RAMASWAMI,, J.

( 1 ) THESE appeals are brought by special leave from the judgment of the orissa High court dated April 22, 1964, in Special Jurisdiction Cases Nos. 27 to 33 of 1963.

( 2 ) THE appellant is a public limited company incorporated in the United Kingdom which has its head office in London and its principal office in India at 16, Netaji Subash Road, Calcutta. . During the relevant period, i. e. , from 1/10/1953, to 30/06/1955, the appellant which is a dealer in machineries, tools and machine parts had supplied these goods to individual consumers and government departments including the Hirakud Dam Project authorities in orissa. The respondent had not levied any sales tax on these transactions till the decision of this court in State of Bombay v. United Motors (India) Ltd. pronounced on 30/03/1953. In that decision it was held by this court that by virtue of the explanation to article 286 (l) (a) of the Constitution, as it existed before the Sixth Amendment, the State where the goods were actually delivered as a direct result of sale or purchase for the purpose of consumption, was the State which had the jurisdiction to tax such sales irrespective of the fact that t