S. B. SINHA, J.

A short but interesting question of law as regards interpretation of sub-section (2-A) of section 20 of the Andhra Pradesh General Sales Tax Act, 1957 (for short, "the Act") arises for consideration in these writ petitions.

All these writ petitions were filed by M/s. Indo National Ltd., Nellore, a company incorporated under the Companies Act, 1956. It is a registered dealer under the Act as also under the Central Sales Tax Act.

It is engaged in the manufacture and sale of dry battery cells of different sizes, which are mostly used for torchlights, transistors, calculators, etc. It has depots or branches at various places in different States throughout the country. Apart from effecting local sales within the State of Andhra Pradesh, the petitioner also sells the goods in the course of inter-State trade as well as by effecting sales outside the State of Andhra Pradesh through its branches and depots. The goods are sent on stock transfer from the petitioner's factories in Nellore district to the concerned branches and the branches sell the goods to the authorised wholesale dealers.

For the assessment years 1978-79, 1979-80 and 1980-81, the assessments were com