JUDGMENT :

A.K. Sikri, J.

In all these appeals, question of law that needs to be decided is identical, which was the reason for clubbing these appeals and hearing them analogously. However, for the sake of convenience, we would be taking note of facts from Civil Appeal Nos. 13047-13048 of 2017, as that would serve the purpose.

2. The respondent (hereinafter referred to as the ‘assessee’) is engaged in the business of manufacturing and selling polymers and chemicals. These goods are manufactured by the respondent in its factory situated in the State of Gujarat (hereinafter referred to as the ‘appellant State’). After the manufacture of these goods, same are transferred by the assessee to its various branches located in different parts of the country from where those goods are sold. Obviously, in respect of goods transferred to places outside the appellant State, the Value Added Tax (VAT) is paid at the time of sale of those goods in those States, as per the local laws of the said States. The goods are sold in the appellant State as well and in respect of these goods VAT is paid as per the Gujarat Value Added Tax Act, 2003 (for short, the ‘VAT Act’). For the purpose of manufacturing the