Inder Dev Dua, J.

1. These four references (G.S.T. Rs. Nos. 1, 2, 3 and 4 of 1962) made by the learned Financial Commissioner under Section 9 (3) of the Central Sales Tax Act (Act 74 of 1956) read with Section 22(1) of the Punjab General Sales Tax Act, 1948, raise the same question of law and have, therefore, been heard together. Main arguments have been addressed in G.S.T. Rs. Nos. 2 and 3; Shri Gandhi has, however, supplemented in G.S.T.R. No. 1 arguments addressed by Shri Sibal in the other two cases.

2. The four questions referred by the learned Financial Commis--sioner may here be reproduced:-

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(1) While not extending the Central Sales Tax Act No. 74 of 1956 to the State of Jammu and Kashmir or in other words not enacting that Act for the State of Jammu and Kashmir, did the Parliament by that Act formulate even its first principle of deter mining, when a sale or purchase of goods takes place in the course of inter-State trade or commerce, qua transaction of sale between dealers of other States of rest of India with those of the State of Jammu and Kashmir ?

(2) Whether by laying down in Section 1 (2), it extends to the whole of India except the State of Jammu and Kashm