MS. R. M. DOSHIT, J. - The petitioner (hereinafter referred to as, "the company") is a company incorporated under the Companies Act, 1956. The company is engaged, inter alia, in the business of manufacturing and marketing of various life saving drugs, pharmaceutical preparations, etc. The company has its manufactory in the State of Gujarat at Vadodara. The company is a dealer within the meaning of the Gujarat Sales Tax Act, 1969 (hereinafter referred to as, "the Act"). The subject-matter of challenge in this petition is the action of the respondents-authorities in issuing notices dated April 12, 2001, February 1, 2002 and September 21, 2002 calling upon the company to show cause why the incidence of sale in question should not be subjected to sales tax under the Act.

The facts leading to the present petition are not disputed. On October 19, 1999, the company sold/assigned certain corporeal rights to one Sarabhai Piramal Pharmaceuticals Limited for a sum of Rs. 34 crores. The necessary documents were executed at Mumbai. It is this transfer of corporeal rights, viz., promotion literature, copy right, technology, etc., which is the subject-matter of controversy. According to