Judgement

HEGDE, J. :- (with him Wanchoo C. J. and G. K. Mitter J.) The principal question canvassed in this group of appeals by special leave is whether S. 11 (4) (a) of the Central Provinces and Berar Sales Tax Act 1947, to be referred to as the Act hereinafter, is ultra vires Article 14 of the Constitution and consequently the notices impugned in the writ petitions from which these appeals arise are liable to be struck down and the respondents restrained from levying sales-tax on the appellants for the period May 1, 1952 to October 31, 1955.

2. The appellants are a private limited company carrying on business inter alia as dealers in iron and steel materials in Vidharba region of the Maharashtra State. In that region they have more than one place of business. They registered themselves as dealers under S. 8-A of the Act and obtained a certificate of registration on August 17, 1947. Their assessment year as shown in their registration certificate is from November 1 to October 31. They were required to submit quarterly returns of their turnovers. They did so till April 31, 1952 Thereafter no returns were submitted. On September 13, 1955, the Assistant Commissioner of Sales-tax, the