Judgment

RAMASWAMI, J. :- These appeals are brought by certificate from the judgment of the High Court of Assam and Nagaland dated April 4, 1963 in Civil Rule No. 90 of 1960 and Civil Rule No. 382 of 1961, whereby the High Court dismissed the petitions under Articles 226 and 227 of the Constitution filed by the appellant.

2. Messrs. Hardeo Das Jagan Nath (hereinafter called the appellant ) is a partnership firm carrying on business at Mawkhar Shillong in the District of United Khasi and Jaintia Hills. By a notification issued under Rule 6 of the Assam Sales Tax Rules 1947, the Commissioner of Taxes, Assam fixed May 20, 1948 as the date by which the dealers of Shillong administered area had not make applications for registration under the Assam Sales Tax Act, 1947 (17 of 1947), hereinafter called the Act . By notification dated April 15, 1948, the Government of India had extended the provisions of the Act with slight modifications to the administered area in Shillong under Section 4 of the Extra Provincial Jurisdiction Act 1947. The appellant got itself registered under the Act. Upto the half yearly return periods ending September 30, 1957, the appellant was assessed to sales-tax an