1The petitioner is the General Manager of the Kannan Devan Hills Produce Company, Ltd., Munnar, which owns several tea estates around Munnar. Its business is "the cultivation, manufacture and sale of tea" produced in its estates, each estate having a factory or factories for the purpose.

2 Under S.6 of the Central Sales Tax Act , 74 of 1956, hereinafter called the Act, every dealer is liable to pay a tax under the Act on all the sales effected by him in the course of inter State trade or commerce.
Under S.7 every dealer liable to pay tax under the Central Act must, and any dealer liable to pay tax under a State Act may, apply for registration under the Central Act; and, if the authority is satisfied that the application is in order, the applicant will be given a Certificate of Registration specifying the classes of goods in respect of which sales tax will be levied at the concessional rate of 1 per cent only; and such certificate may be amended or cancelled on sufficient reason by the issuing authority.
The effect of Sub-s.(1) of S.8, read with sub-s.(3) is that, if the buyer be a registered dealer, and the goods be not of a class declared in S.14, the concessional rate of sales tax

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