The judgment of the Court was delivered by

MADON, J. - These are three references under section 9(2) of the Central Sales Tax Act, 1956 (hereinafter for the sake of brevity referred to as "the Central Act"), read with section 61(1) of the Bombay Sales Tax Act, 1959 (hereinafter for the sake of brevity referred to as "the Bombay Act"), which give rise to common questions of law.

The applicants were at all material times registered as dealers both under the Central Act and the Bombay Act. They carried on the business of bleaching and printing fabrics manufactured by them for sale as also bleaching and printing fabrics manufactured by others for sale. For this purpose the applicants used to purchase grey fabrics, dyes, caustic soda and other processing materials. So far as the purchase of these materials from outside-State dealers were concerned, the applicants used to purchase such materials on declarations given by them to their vendors, stating that the goods as purchased were intended for use by them in the manufacture or processing of goods for sale. Under the provisions of the Central Act in force when such declarations were given, the rate of tax applicable was 2 per c