The basic issue that we must decide at the threshold is whether the subject appeals are maintainable and whether we can proceed to decide these appeals on merits.

2. The assessee before us is a public sector undertaking, and, as the name itself suggests, it is a State public sector undertaking. Although what is argued before us was that fifty per cent of its share capital is held by the Central Government and remaining fifty per cent share capital is held by the Maharashtra State Government, from the information available in the public domain itself, it appears that a fifty per cent of its shares are held by the State Government and the remaining fifty per cent by a Central Government undertaking by the name of Central Warehousing Corporation Ltd. There is thus little dispute about the basic position that the assessee is a State Government public sector undertaking—something which is vehemently denied by the counsel appearing for the assessee.

3. In the case of Oil & Natural Gas Commission v. CCE [1992] 104 CTR (SC) 31, Hon'ble Supreme Court expressed dissatisfaction with the fact that intra-Government litigation between various organs of the Government of Ind