JUDGMENT

B. N. MAHAPATRA, J. — In this writ petition the petitioner challenges the revisional order dated 13.3.1992 passed by the Addl. Commissioner of Sales Tax, Orissa (hereinafter called as the ‘revisional authority’) in Revision Case No. SA.517/91-92, confirming the order dated 30.10.1989 passed by the Sales Tax Officer (hereinafter called as ‘the S.T.O.), Sambalpur-III Circle, Jharsuguda, imposing penalty of Rs. 37,00,000/- under Section 10-A of the Central Sales Tax Act, 1956 (hereinafter referred to as the ‘C.S.T.Act’).

2. In nutshell, the background facts which are relevant for the purpose of dealing with this writ petition are as follows :

The petitioner is a Company incorporated under the Companies Act, 1956 having its registered office at Seepat Road, Bilaspur in the State of Madhya Pradesh and is a subsidiary of Coal India Ltd. It has an unit in Brajarajnagar in the district of Sambalpur (Orissa) and it is a Government of India undertaking. The business of the petitioner is to extract coal from the Mines both underground and open cast and to effect sale thereof. To carry on its business the petitioner registered itself both under the Orissa Sales Tax Act, 1947 (hereina