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2. T. R. C. 1/62 is against the order of the Sales Tax Appellate Tribunal Appeal No. 472 of 1960; T. R. C. 2/1962 is against T. A. 299 ot 1960; T. R. C. No. 3/1962 is against T. A. 471 of 1960 and T, R. C. 4/1962 is against T. A. 470 of 1960, and they relate respectively to assessments for the years 1955-56, 1956-57, 1954-55 and 1953-54. The petitioner in all these eases is Thungabhadra Industries Limited, which has factory at Kurnool, which purchases groundnut and groundnut Kernel and manufactures amongst other things groundnut oil, refined oil and hydrogenated oil for sale within the State and outside the State of Andhra Pradesh. In the transactions with which we are concerned, the petitioner imported groundnut kernel from dealers outside the State in pursuance of a contract of sale entered into between the parties and thereafter converted the kernel into oil of three types, namely, raw groundnut oil, refined oil and hydrogenated oil. Before the Appellate Tribunal, the petitioner raised the following contentions:

18. Now we torn to the second contention of the petitioner, namely, that the Appellate Tribunal was in error in holding that the transactions in question constituted intra-state sales and not inter-state sales. On this point the Tribunal examined the terms of a specimen contract and held that as the sales were completed within the State subsequent to the delivery of the goods at the premises of the petitioner and the property in the goods passed only after weighment and various tests which were done at Kurnool, the sales in question could not be regarded as having taken place in the course of inter-state trade. We are satisfied that this view of the Tribunal is palpably erroneous and does not accord with the crucial test formulated by the Supreme Court in a catena of cases. We need only refer to a recent decision of the Supreme Court in Cement Marketing Co. of India (Private) Ltd. v. State of Mysore, in the course of which the entire case law was reviewed and the position was summed up thus at page 182 (of STC): (at p. 984 of ATR):