JUDGMENT

Santosh Hegde, J.-When the State of Haryana tried to impose sales-tax on levy transactions undertaken by the appellant in the year 1973, the same was challenged by the appellant before the Punjab & Haryana High Court on the ground that the said transactions did not amount to either purchase or sale. The High Court of Punjab as per its judgment dated 17th May, 1975 following a judgment of this Court in the case of M/s. Chitter Mal Narain Dass v. C.S.T.1, allowed the said writ petition and declared that the State of Haryana did not have the constitutional authority to impose sales-tax on levy transactions, consequently, it quashed the assessment orders and demand notices issued by the State. This judgment was not challenged by the State of Haryana, hence, remained to be the declared law so far as the State of Haryana is concerned.

2. Subsequently, in the year 1982 even though the above referred judgment of the Punjab & Haryana High Court remained to be a good law, the State of Haryana again issued a demand notice to the appellant levying sales-tax on the turn over involving levy transactions. A challenge to the said demand notice by the appellant came to be rejected by the Pun