JUDGMENT

Satish Chandra, J. - Between August, 1947, and February, 1955, the Railway Administration at Allahabad imported large quantities of foodgrains and cereals which were liable to octroi duty payable to the Municipal Board of Allahabad. The Railway Administration imported these goods through contractors as well as itself directly. It also purchased these commodities from the Town Rationing Officer, Allahabad. The Municipality claimed that a sum of Rs. 62,944.81 was payable by the Railway Administration as octroi on goods imported through the contractors. Out of this Rs. 30,048.87 has been realised leaving a balance of Rs. 32,895.94. The Municipality claimed that a sum of Rs. 19,737/3/- was due from the Railway Administration on account of goods imported by it directly. The Railway Administration had paid a sum of Rs. 494/5/- leaving a balance of Rs. 19,242/14/-. The Municipality claimed that a sum of Rs. 51,728.65 was payable by the Railway Administration on account of goods purchased from the Town Rationing Officer.

2. The Railway Administration denied its liability to pay octroi for goods purchased from the Town Rationing Officer on the ground that the Town Rationing Officer