JAGADISAN, J.

This is petition under Article 226 of the Constitution for the issue of a writ of prohibition against the Deputy Commercial Tax Officer, Special Circle, Non-resident, Madras, restraining him from proceeding with the collection of sales tax as per his communication No. S.10/39/BLR dated 8th May, 1959, in respect of the assessment year 1954-55 under the Madras General Sales Tax Act.

The petitioners constitute a firm of partnership carrying on business in silk yarn at Avenue Road, Bangalore. They are residents of the Mysore State. During the years 1953 to 1955, they effected sales of consignments of silk yarn in this State. They claimed to be immune from the levy of sales tax either in the State of Mysore or in this State, on the grounds that their transactions of sales referred to were inter-State sales governed by Article 286 of the Constitution. After the decision of the Supreme Court of India in the United Motors case and as a result of Central Act VI of 1956 (the Sales Tax Laws Validation Act), and section 22 of the Madras General Sales Tax Act, the inter-State sales effected by the petitioners in this State, in which the deliveries of goods sold were made