S.B. WAD, J.

In this reference under section 21(1) of the Bengal Finance (Sales Tax) Act, 1941, the following questions are referred by the Lt. Governor, Delhi, for our opinion :

"(i) Whether, on the facts and in the circumstances of the case, the sales of coal and coke made to various coal retailers of the Union Territory of Delhi by the dealer by endorsing the railway receipts in their favour while the goods were in movement constitute single transaction of inter-State sales falling within the purview of section 3(b) read with explanation 1 of the Central Sales Tax Act, 1956, or their are two sales (i) one between the colliery owners and the dealer falling under clause (a) of section 3 of the Central Act and the other between the dealer and retailers in Delhi ?

(ii) Whether, on the facts and in the circumstances of the case, the second sale of coal by the dealer by endorsement of the railway receipts to the retailers in Delhi is subsequent inter-State sale falling under clause (b) of section 3 of the Central Act or inter-State sale falling under clause (g) of section 2 of the Act ?

(iii) Whether, on the facts and in the circumstances of the case, the subsequent inter-Sta