Ramaswami, J.

1. In this case the assessee, Messrs. B. N. Guha and Company, is an incorporated body with its registered office at Calcutta. The Company has taken lease of timber forest in Nepal and has built godowns and offices in Nepal territory close to the Jogbani railway station in Bihar State. The Company manufactures timber sleepers, squares, logs etc., at their workshop. The Company has taken a big railway contract and the bulk of the timber manufactured by it is supplied to the Railways and despatched to different destination from Jogbani railway station after obtaining instructions from the Sleeper Control Office. For the period from 1-7-1947 to 31-3-1948 the Sales-tax Officer determined the taxable turnover to be Rs. 4,50,061 and imposed sales-tax amounting to Rs. 7,032/3/-. The objection of the Company was that no sale took place in Bihar since the wooden sleepers were manufactured in Nepal and despatched from Jogbani Railway station to places outside the Bihar State. It was conceded on the part of the assessee that the goods were stored in its godown at Jogbani so long as wagons were not available. But the contention of the assessee was that the sale did- not ta