Judgment

S.B. SINHA, J. - Leave granted.

2. The appellant herein is engaged, inter alia, in the printing of question papers for examination boards, competitive examination boards, recruitment boards and various universities and boards situate outside the State of Uttar Pradesh. It carries on a highly specialised and secretive work. The activities of the appellant admittedly amount to a works contract in the course of inter - State trade or commerce.

3. The Central Sales Tax Act, 1956 (for short "the 1956 Act") was enacted to formulate principles for determining when a sale or purchase of goods takes place in the course of inter - State trade or commerce or outside a State or in the course of imports into or export from India, to provide for the levy, collection and distribution of taxes on sales of goods in the course of inter - State trade or commerce.

4. The said Act did not contain any provision to levy tax on works contract, despite insertion of clause (29 - A) in Article 366 of the Constitution of India. The question of levy of sales tax on works contract, inter alia, came up for consideration before this Court in Gannon Dunkerley and Co. v. State of Rajasthan 1. While notici