1. Is the transfer of the right to use any goods for any purpose (whether or not for a specified period) for cash, deferred payment or other valuable consideration, subject to levy of sales tax under the Tripura Sales Tax Act, 1976 (in short, "the TST Act") and if so, who is liable to pay such a tax, are two important questions raised in this series of appeals.

2. Yet another question, raised in the present set of appeals, is as to whether Sub-rule (2) of Rule 3A of the Tripura Sales Tax Rules, 1976 (in short, "the TST Rules"), can be treated to be a valid piece of delegated legislation, when it mandates every person, responsible for making payment to the transferor of the right to use any goods for any purpose (whether or not for a specified period), to deduct an amount equal to four per centum of the dues of such a transferor towards part or full satisfaction of the sales tax payable, under the TST Act, on account of such transfer of the right.

3. Before we make endeavour to answer the questions posed above, it is imperative that some material facts, which have given rise to the present appeals, are taken note of. These facts are, in brief, set out as under:

(i) Being in nee