JUDGMENT

Rajendra Babu, J.-The appellant before us is Hindustan Aeronautics Limited situate at Sunebeda in Koraput District, Orissa State. They possess several vehicles which are assessed to tax under Item No. 6 of the Schedule annexed to Orissa Motor Vehicles Taxation Act, 1986 (hereinafter referred to as the Act ). In respect of vehicles bearing registration Nos. ORK 3597, ORK 3810, ORK 5638, ORK 5639 and OSK 1563 proceedings were initiated by the Taxing Officer under the Act. On February 22, 1991 the Tax Inspector, Orissa Motor Vehicle Department, stopped and checked the vehicles bearing registration Nos. ORK 3597 and ORK 3810 and the remaining three vehicles on March 4, 1991 while proceeding from Sunabeda to Koraput carrying college students and employees. He issued a vehicle check report stating that the vehicle was being used for hire and reward as contract carriage and seized the vehicle. The vehicle was released on March 4, 1991 on payment of differential tax for different periods. A notice was issued to the appellant to clarify (i) the date from which the bus was plying to Koraput or to school at Sunabeda; (ii) amount of fare collected from each student for such journey fr