B. N. Srikrishna, C. J.

This appeal is directed against the judgment of the learned Single Judge dated 18th December, 1992, quashing and setting aside a penalty order imposed on the respondent by Exts. P6 to P6(s).

The appellant is a company incorporated under the Companies Act, 1956. On 3rd July 1976, the appellant purchased tea estates of three companies known as Kannan Devan Hill Produce Co. Ltd., Anglo American Direct Tea Trading Co. Ltd., and Amalgamated Tea Estates Ltd. These three companies were registered in the United Kingdom and for the sake of brevity they are hereinafter referred to as "U. K. Companies".

2. The concerned officer of the Sales Tax Department issued three registration certificates which were valid from 1. 7.1957 until cancelled. The respondent has been issued with notices by the Agricultural Income Tax and Sales Tax Officer, Munnar for offences alleged to be under S.10(a) and 10(d) of the Central Sales Tax Act, 1956, (hereinafter referred to as "the Act") committed by the three U. K. Companies between 1967 and 1973, arising out of different orders passed against the said companies on different dates. The three U. K. Companies held registrations un