'958 Dhansiram of Calcutta, an unregistered dealer, it came MahadaJ·al to the notice of the Assistant Commissioner, (C.S.) that Prem,handm the said dealer had purchased woollen goods worth v. Hs. 59,530-13 during the period from November 20, Coa1me»,;a1 Tax 1952, to December 18, 1952, from M/s. British India Offim, Calrnlla Corporation Ltd., Kanpur 'Woollen Mills Branch. Invoices, copies of which were enclosed therewith, hp,d Bhagwali ]. been drawn by the British India Corporation Ltd., for Kanpur Woollen Mills from Kanpur and the goods in question were reported to have been despatched to M/s. Khubiram Dhansiram from Kanpur. Orders Nos. quoted in the invoices were the Nos.-of orders placed to Kanpur Woollen Mills by their sole agents in Vil est Bengal, the appellants herein, and the Assistant Commissioner (C.S.) was of the opinion that under Explanation 2 of s. 2(g) of the Act, the sales of K~npur Woollen Mills from Kanpur as referred to above should be deemed to have taken place in West Bengal and under.Explanation 3 of s. 2(c) of the Act the appellants should be deemed to be tlie dealer in West Bengal on account of the sales of Kanpur Vi' oollen Mills and as such were liable to pay the tax at that end. The Assistant Commissioner (C.S.), therefore, asked the first respondent by his letter dated January 21, 1953, to verify as to whether the appellants had accounted for those transactions in their books of account and had paid the taxes due by them.
