The short facts leading to this writ appeal are as follows :

2. The appellant is a private limited company. Apart from owning tea estates, it also manages tea estates and is carrying on business in growing as well as manufacturing tea. Besides, it is also a registered exporter of coffee having been registered with the Coffee Board, the first respondent herein. The said Board is a statutory one constituted under the Coffee Act, 1942. It is empowered to control and develop the entire coffee industry in this country.

3. The appellant was able to secure an order for supplying 2, 000 tonnes of coffee powder from Romania. In order to effect that supply, the appellant bid at an export coffee auction held by the first respondent. The appellant was the highest bidder and the auction was knocked in its favour. Accordingly, the price was also paid. Even at the time of participating in the auction and the payment of money, the Board knew that the participation by the appellant was to fulfil the order of the foreign buyer for coffee powder and that the same was exempt under the proviso to section 6(1) of the Central Sales Tax Act, 1956 (hereinafter referred to as "the Act") read with