KANAKARAJ, J.

On scrutiny of the accounts of the petitioner-assessee for the assessment year 1976-77, it was found that they had effected inter-State sales of steam coal, even though the assessee did not submit returns under the Central Sales Tax Act, 1956. Collieries in Andhra Pradesh and other States despatched coal by rail to Salem, where the collieries figured as consignors and the assessee as consignees. Actually the orders for supply of coal were really placed by another society at Madras. The assessee had placed orders on the Madras society. Even the assessee did not take delivery of the goods and they in turn endorsed the railway receipts in favour of the local buyers who apparently were members of the assessee-society. Those buyers took delivery of the goods at the Salem railway station.

2. The assessee had effected such inter-State sales to the tune of Rs. 2, 03, 508.83. Thus the sales of coal by the assessee-society, by transfer of documents of title to goods, took place during the movement of coal from Andhra Pradesh State to Tamil Nadu State and those sales by the assessee were inter-State sales falling under section3(b) of the Central Sales Tax Act, 1956

3. I