The judgment of the Court was delivered by

G. T. NANAVATI, J. - The petitioner-company is having its registered office at Bombay and its head office and factory at Baroda. It is registered as a "dealer" under the Central Sales Tax Act, 1956 (hereinafter referred to as "the Central Act") as well as the Gujarat Sales Tax Act, 1969 (hereinafter referred to as "the Local Act"). The petitioner sells its goods within and outside the State of Gujarat. It has branch offices at various places in India. At places where the petitioner has branch offices, the petitioner despatches goods to its branch offices from time to time and the said branch offices subsequently sell the goods in the State in which they are located. The said sales effected by the branch offices are subjected to local sales tax by the States, wherein the branch offices are located. In respect of the sales effected directly by the petitioner in other States, the petitioner pays sales tax under the Central Sales Tax Act. It is subjected to tax under the Gujarat Sales Tax Act in respect of the sales effected by it within the State of Gujarat. It appears that, some transactions, which the petitioner described as "branc