Aftab Alam, J.

1. Whether in order to qualify for the benefit of concessional rates of purchase in terms of Sec. 13(1)(b) of the Bihar Finance Act, 1981 (the Act, hereinafter) the dealer, apart from satisfying the other conditions specified in the section, must also have the site of manufacture in which the purchased goods are to be used located within the State?

2. Or to say the same thing slightly differently; is it sufficient for the purpose of Sec. 13(1)(b) that the goods purchased at concessional rates are directly used in the manufacture of goods though for being used in the manufacture, the goods purchased in this State are transported out side the State where the manufacturing unit is sited? This is the question that arises for consideration in this writ petition.

3. The petitioner is a company registered under the Companies Act. It has its registered office at Bombay and a manufacturing unit at Renukoot in the State of U.P. where it is engaged in the manufacture of aluminium and allied products. It is stated on behalf of the petitioner that bauxite is one of the major raw materials required for manufacturing aluminium and the petitioner has got several mines within