ORDER A. M. Sapre, J. - The decision rendered in this writ shall govern disposal of other two connected writs filed by the petitioners being W.P. Nos. 143 and 144 of 2005, because in all the three writs, the issue involved is the same except the difference being that of period of assessment under the provisions of the M.P. Commercial Tax Act, 1994 read with the Central Sales Tax Act, 1956. By filing this writ under article 226/227 of the Constitution of India, the petitioner seeks to challenge the revisionary order (common in all the three writs) dated January 29, 2004, passed in Revision No. 53/2003/State/Indore and Revision No. 21/2003/Central/Indore (annexure P18) by the Additional Commissioner, Commercial Tax, Indore, which in its turn arise out of the respective assessment years as mentioned in the respective assessment orders. The petitioner (a dealer) is engaged in the business of manufacture and sale of what is called - steel tubes, having their unit at Dewas and office at Indore. They also claim to have several branches all over India. On August 27, 1993, the flying squad of Commercial Tax Wing of State raided the business premises of the petitioner and collected/seized several incriminating documents. In this raid, statements of employees working in the petitioner's unit were also recorded with a view to ascertain the nature of documents and also the nature of transactions entered into and accomplished by the petitioner during the period in question so that tax liability, if any, can be determined. This led to making of assessment of the petitioners for the period in question. It is in these proceedings, the question arose, whether certain sales transactions which were discovered to have been executed by the petitioner were in the nature of branch transfer, i.e., stock transfer to their respective branches or they were in the nature of inter-State sales to their specific buyers ? It is essentially this question which was examined on facts and with reference to evidence collected such as seized documents/statement of employees recorded in raid proceedings. In the opinion of assessing officer and later upheld by revisionary authority by impugned orders, the transactions in question were held essentially in the nature of sales and being effected from one State to another, they were regarded as "inter-State sales" for being taxed accordingly under the Central Sales Tax Act read with State Act. In the opinion of assessing officer and later upheld by revisionary authority by impugned orders, the transactions in question were held essentially in the nature of sales and being effected from one State to another, they were regarded as "inter-State sales" for being taxed accordingly under the Central Sales Tax Act read with State Act. In other words, the transactions in question were not held as stock transfer and/or what is called branch transfer as alleged by the petitioner (assessee/dealer) so as to take them out from the clutches of the tax net but were held as inter-State sales. It is this finding which is sought to be impugned by the petitioner in these petitions. Notice of these writs was issued to the respondent. They are served and represented. Return has been filed, inter alia, justifying the impugned orders including the factual finding returned by the two authorities holding the transactions to be in the nature of inter-State sales and not a mere branch transfer. Heard Shri P. M. Choudhary, learned counsel for the petitioner and Shri A. S. Kutumble, learned Additional Advocate-General with Shri M. Parwal, penal lawyer for the respondent-State. Placing reliance on the decision reported in the case of Ashok Leyland Ltd. v. State of Tamil Nadu [2004] 134 STC 473 (SC), learned counsel for the petitioner contended that both the authorities, i.e., the assessing officer and the revisionary authority erred in holding that the transactions in question are not branch transfer. According to learned counsel, the documents filed including relevant forms, clearly indicate that the transactions in question were in the nature of branch transfer and thus, did not involve any element of sale as such. Learned counsel further contended that in the earlier round of litigation, certain documents were held as not relevant and hence, the assessing officer was bound by the said finding so recorded by the revisionary authority. It is essentially these submissions which were elaborated with reference to orders impugned and case law relied on. In reply, learned Additional Advocate-General defended the impugned orders by placing reliance on the findings recorded as also the admission of the petitioners admitting the transaction to be in the nature of inter-State one. Having heard learned counsel for the parties and having perused the record of the case, I am of the view that no interference in the impugned orders are called for. Having heard learned counsel for the parties and having perused the record of the case, I am of the view that no interference in the impugned orders are called for. As a consequence, the petition fails and is hereby dismissed. In my considered opinion in the facts and circumstances of the case, the issue in relation to transactions in question was rightly held to be a case of inter-State transaction effected by the petitioner during the period in question. In fact, whether a particular transaction effected by the assessee is "inter-State sale" or "intra-State sale" or "branch transfer" involving no element of sale is question of fact and needs to be decided on the basis of documents/material available on record. If on the basis of material available, i.e., filed by the parties or seized by the department in raid, a factual conclusion can be drawn in regard to its nature, then such finding of fact cannot be disturbed by a writ court though challenged by the assessee on facts. Coming to the facts of this case, it is not in dispute that several incriminating documents which had been seized in clear terms revealed that the goods manufactured by the petitioner at their Dewas unit were meant for specific buyers situated at different places of the State of M.P. The names of buyers were identified. Even the statement of Mr. Mehta, the employee of the petitioner which was recorded on the date of raid (annexure R1) clearly admitted that the goods in question were meant for sale to the parties concern outside State. In addition, several other materials such as code number of these buyers, etc., which were seized also clearly established the nexus of sale between the petitioner and the buyer situated in other States. An inference of concluded sale having taken place between the assessee and buyer can always be drawn on several material facts brought on record. Once the documents on record are held sufficient to record a finding of sale in the nature of inter-State sale then such factual finding is beyond challenge in writ. It is not a finding which can be regarded as finding de hors the legal principle or against the evidence on record. In my view, the law laid down in Ashok Leyland case [2004] 134 STC 473 (SC) is general in nature. Its applicability differs from case to case. It is not a finding which can be regarded as finding de hors the legal principle or against the evidence on record. In my view, the law laid down in Ashok Leyland case [2004] 134 STC 473 (SC) is general in nature. Its applicability differs from case to case. In fact, even in Ashok Leyland [2004] 134 STC 473 (SC) factual inquiry is insisted upon for deciding the true nature of transactions before they are brought into the tax net. In this case, as taken note of supra, the inquiry was held and several documents seized were considered for recording a finding against the petitioner. I am not impressed by the submission of learned counsel when he contended that certain forms to show branch transfer were not considered or that some material having been rejected by the revisionary authority in the earlier round of litigation, the same could not have been taken note of. In my considered view this submission is raised for mere argument sake involving no legal basis. Mere perusal of impugned revisionary order would indicate that each and every transaction in relation to each specific party was examined. That mentioned even the name of buyer. It is coupled with the admission of petitioner's witness - Mr. Mehta (R1). What more clinching and conclusive evidence was required for recording a finding of concluded sale (inter-State) against the petitioner. The entire object of the inquiry is to find out the true nature of transaction. It varies from case to case as to what material is relied on or needed to hold the nature of transaction to be "A" or "B" or "C". In my opinion, once the case is remanded then the assessing officer has full power to go into each and every document seized as also relied on by the assessee for recording a finding one way or other. Learned counsel for the petitioner then contended that once the tax has been paid by the branch the impugned orders become bad in law. I find no merit. Firstly, no such plea was raised before authorities. Secondly, there is nothing on record to justify the impugned order already passed. In view of aforesaid discussion, I am unable to notice any infirmity in the impugned orders. As a result, the petition fails and is dismissed.