These are two connected suits filed by the East Asiatic Company Ltd., against the State of Madras, represented by the Collector of Madras for an injunction restraining the defendant or any or its officers or servants from demanding, collecting or realising from the plaintiff the sum of Rs. 14, 102-5-4 and Rs. 18, 295-12-6 or any part thereof being the additional sales tax sought to be illegally levied on the plaintiff for the years 1945-46 and 1946-47.

2. The case for the plaintiff is : The plaintiff during the assessment years 1945-46 and 1946-47 bought and crushed groundnut kernels as manufacturer of groundnut oil and cake and effected sales and delivery of part of groundnut oil so manufactured outside the Province. The total turnover of the oil so sold and delivered outside the Province of Madras in 1945-46 was Rs. 18, 29, 578-4-1 and Rs. 14, 20, 234-1-0 for the year 1946-47. The Deputy Commercial Tax Officer, Harbour Division, Madras, did not assesss to sales tax these two turnovers relating to sale outside the Province of Madras. The Commercial Tax Officer, North Madras, on 3rd July, 1947, confirmed this order of the Deputy Commercial Tax Officer. On 4th March, 1950