SHARMA, J. - Whether Government Medical Store Depot, Karnal (hereinafter referred to as the depot) is a dealer within the meaning of section 2(d) of the Punjab General Sales Tax Act, 1948 (hereinafter referred as the Act) or not is the short point involved in Civil Writ Petitions Nos. 1183, 1184, 1795, 1796 and 1797 of 1970, which are all being disposed of by this judgment.

It is alleged that the depot is functioning under the Assistant Director General (Stores), who is in-charge of Medical Stores Organisation in the whole of India under the Director-General of Health Services, Government of India. Ministry of Health, New Delhi. It is a department of the Central Government and supplies medicines and hospital equipments manufactured in India and imported from abroad to Government hospitals, Government institutions, health centres, dispensaries and primary health units located in northern India, some of which are run by self-governing bodies like panchayats, panchayat samities, zila parishads and municipalities. It does not deal with private hospitals and individuals. It is further averred that the organisation is working as a public utility service on "no-profit-no-loss" ba