( 1 ) ON a reference made by one of us, these cases were posted before a Division bench for disposal.

( 2 ) A statutory Board called 'the coffee Board' ('the Board') which was formerly called the Indian Coffee Market expansion Board constituted and functioning under the Coffee Act of 1942 (Central Act VI of 1942) ('the Coffee act') is the common petitioner before us and the principal question that arises for our determination is whether it is exigible to purchase tax or not under Section 6 of the Karnataka Sales Tax Act of 1957 (Karnataka Act 25 of 1957) ('kst Act' ). In order to decide that principal and certain other allied questions, it is necessary to notice the facts that are not also in dispute in the first instance.

( 3 ) ON the out break of the II World war, the Indian Coffee that enjoyed precious export markets in European and other advanced countries lost them and the industry was facing a crisis. With the object of rehabilitating the industry and placing it on a sound footing, accepting the recommendations of a conference held thereto, the then Viceroy and governor General of India, promulgated the Coffee Market Expansion Ordinance (Ordinance No. 13 of 194