Apparently the appellants understood this order as ill anuf acl1'rers acl1'rers meaning that all sales, whereunder goods were deli- (Indiai Ltd. vered outside the State, whether or not for consumpv. tion in the State of first delivery (i.e., both types (a) & The Commisoioner (b)) were exempted from the tax levy. The sales-tax 0 ! Sales-1,,x, authorities, however, took the order to mean that only B·ilrnr, Putua those sales in which deliveries were made outside the Ayyangar J. State for consumption in the State of first destination, i.e., those of type (a) were intended to be exempted, and these rival interpretat.ions were put forward in the correspondence that passed between the appellant!! and the s1tles-tax authorities. The appellants made an application for the refund of the amount of tax attributable to all the sales under which goods were delivered outside the State, but the tax authorities sticking to their interpretation of the order of the Board and of their interpretation of the decision of this Court. in the United Motors case (1) refunded the tax collected on the sales falling within type (a) but refused to refund Rs. 20,923-15-2 for the 1st year and Rs. 1,29,823-5-0 for the later year-these amounts representing the tax on sales of type (b). The appellants however persisted in pressing their claim for the refund of these amounts also. In this state of affairs, the State of Bihar moved the Boa.rd of Revenue to review its order dated August 28, 1953, or at any rate clarify it so as to confine its operation to sales falling within type (a), urging that this would bring it in accord with the interpretation of Art. 286(1) by this Court in the United Motors case (1). The appellants objected to the jurisdiction of the Board of Revenue to review its previous decision and on April 25, 1955, it passed the following order:
