Ramachandran Nair, J.

These connected Tax Revision Cases arise from the common order of the Tribunal sustaining sales tax assessments of the petitioners under the KGST Act for the year 1991-92. All the petitioners have held registration under the Pondicherry Sales Tax Act in Mahe during the year 1991-92. Mahe is a Union territory area under Pondicherry in Kerala with a square area of around 5 sq.kms. and a population of around 30,000. Several cases reaching this Court prove that Mahe is used as a pocket for evasion of sales tax legitimately due to the State of Kerala. In fact most sales accounted in Mahe take place in Kerala in a clandestine manner. This is because relatively much lower rate of tax is payable on goods under the Pondicherry Sales Tax Act. Therefore tax which would not otherwise be due to that Govt. gets paid there on account of parties accounting Kerala-sales in Mahe. For example, the product involved in this case is ghee, rate of tax for which in Kerala during the relevant year was 10% whereas the rate of tax in Mahe was 1%. On enquiry with the seller for RKG brand ghee at Kankeyam in Tamil Nadu, the Sales Tax Intelligence Department in Kerala got the in