BHANDARI, J.

( 1 ) THIS is a Writ petition under Article 226 of the Constitution by Messrs. Shiv Ratan G. Mohatta which is a partnership Firm having its office at Station Road, jodhpur, for quashing the order of assessment dated the 5th of March 1962 (Ex. 2 on the record) passed by the Sales Tax Officer, Jodhpur City Circle Jodhpur (Respondent No. 1) with respect to the assessment year 1958-59 to the extent it seeks to charge sales tax on the turnover of Rs. 23,92,252. 75 np. which sum according to the petitioner, represents the price realised on account of the sale of the cement imported from Pakistan as agent of Shri State Trading Corporation of india Private Ltd. , New Delhi (hereinafter called the State Trading Corporation ). The relevant facts relating to the import of the Pakistan cement are mentioned in paragraph 9 of the petition and are not denied in the reply filed by the Slate of rajasthan who is Respondent No. 2 and must also he taken to be admitted by respondent No. 1. The Zeal Pak Cement Factory, Hyderabad (hereinafter called the Pakistan Factory) manufactured cement in Pakistan. For the export of this cement from Pakistan, the Pakistan Industrial Development