Bal Raj Tuli, J.

1. This order will dispose of General Sales Tax References Nos. 30, 31 and 32 of 1971. G. S. T. R. No. 30 relates to the assessment year 1964-65, while G. S. T. R. Nos. 31 and 32 relate to the assessment year 1965-66.

2. The facts are that the assessee, Messrs. South Punjab Electricity Corporation Ltd. now named as Rohtak Textile Mills Ltd., Rohtak, is a public company registered under the Companies Act, with its registered office at Delhi. It is engaged in the business of manufacture and sale of cotton yarn and has its spinning mills, known as Mohan Spinning Mills, at Rohtak for the manufacture thereof. It is registered under the Punjab General Sales Tax Act as well as the Central Sales Tax Act, 1956, at Rohtak. It maintains sales office and godown at Delhi besides the one at Rohtak: For the assessment year 1964-65, the assessee showed gross turnover of Rs. 76,17,823.15 out of which it claimed deductions amounting to Rs. 52,84,985.61, as transfer of cotton yarn from the factory at Rohtak to its sales office at Delhi.

3. The Assessing Authority examined the transactions relating to the deductions claimed from the account books, stock registers and other doc