Judgement

SHAH, J. (for himself, Sinha C.J.I. and Imam, J.) : By this petition for writs of certiorari and mandamus, the Tata Iron and Steel Co., Ltd., hereinafter referred to as the company, challenges the authority of the Commercial Tax Officer, Lyons Range, Calcutta to demand payment of Rs. 41,14,718-12 nP. to the West Bengal Government as tax leviable under the Central Sales Tax Act No. 74 of 1956 in respect of certain sales of steel goods.

2. The company has its registered office in Bombay, its Head Sales office in Calcutta in the State of West Bengal and its factories in Jamshedpur in the State of Bihar. The company is registered as a " dealer under the Bihar Sales Tax Act, and is also registered as a " dealer in the State of West Bengal under the Central Sales Tax Act, 1956. For the period of assessment July 1, 1957 to March 31, 1958, the company submitted its return of taxable sales to the Commercial Tax Officer, Lyons Range, Calcutta disclosing a gross taxable turnover of Rs. 9,561-71 nP. in respect of sales liable to Central Sales tax in the State of West Bengal. By his memorandum dated August 12, 1959, the Commercial Tax Officer directed the company to submit a statement o