The judgment of the Court was delivered by

MADON, J. - The respondents were registered as a dealer under the Bombay Sales Tax Act, 1959, and carry on the business of manufacture of "vanaspati", soap and other articles at Akola, their principal article of manufacture being hydrogenated vegetable oil. The respondents had also obtained a recognition under section 25 of the said Act. For the purpose of their manufacturing business the respondents used to purchase raw materials. For the assessment period 1st January, 1960, to 31st July, 1960, the respondents made total purchases of the aggregate value of about Rs. 1,97,72.293. Out of these total purchases, purchases of the value of Rs. 1,15,80,625 were made by the respondents by giving certificates in form 15 to the Bombay Sales Tax Rules, 1959, while the remaining purchases of the aggregate value of Rs. 81,91,668 were made otherwise than by giving a certificate in the said form 15. Under clause (b) of section 12 of the Bombay Sales Tax Act, 1959, as in force during the assessment period, when a dealer holding a recognition, who is referred to in the said Act as a "recognised dealer", makes purchases of goods mentioned in the s