Iqbal Ahmed Ansari, J.

1. This writ petition, made under Article 226 of the Constitution of India, has put to challenge the constitutional validity of certain provisions of the Tripura Sales Tax Act, 1976, (in short, the TST Act, 1976) to the extent that the same permits imposition of tax on the transfer of right to use goods. The prominent challenges, in the present writ petition, are to the constitutional validity of Section 2(b), which defines the term dealer, Section 2(d), which defines the term sale and Section 3 of the TST Act, 1976, which contains the charging provisions.

Facts of WP(C) 127 of 2005

2. The material facts, which have led to the institution of the present writ petition, may, first, be noted. In response to the NIT, floated by preformed Respondent No. 4, namely, Oil & Natural Gas Corporation Ltd., AD Nagar, West Tripura, Agartala, (in short, the ONGC), for the work well logging, perforating and other wire line services for its Oil & Natural Gas Exploration and Exploitation to be carried out On land in the States of Gujarat, Tamil Nadu, Andhra Pradesh, Pondicherry, Madhya Pradesh, Rajasthan, Assam, Nagaland, Tripura, etc, under the jurisdiction of the Union