D.K.Mahajan, J.

1. This order will dispose of Civil Writ Petitions Nos. 914, 915 and 916 of 1962. The controversy in all of them is identical but three petitions have been filed because they pertain to three separate assessments for three separate years. The first petition relates to the assessment for the year 1957-58, the second for the year 1958-59 and the third for the year 1959-60. The assessee is New Rajasthan Mineral Syndicate which is registered under the Punjab General Sales Tax Act, 1948. The firm is not registered under the Central Sales Tax Act, 1956. This firm carries on the business of quarry contractors and extracts iron ore from quarries. According to the petitioner the ore is actually meant for export to Japan, and other foreign countries. In paragraph 3 of the petition it is stated that the Government of India have appointed the State Trading Corporation as their nominee for the purpose of exporting iron ore from India to Japan and other countries. The petitioner-firm or any other private dealer is not competent to export any ore outside India. The method of exporting iron ore is stated as follows: The petitioner extracts ore, out of which, ore of certain