Judgment

ALAGIRISWAMI, J.:- These matters have been argued twice, once by Mr. K. Sen on behalf of the petitioners in W. P. Nos. 112, 391-394 of 1971 and again by Mr. N. A. Palkhiwala on behalf of the petitioners in W. P. Nos. 330-331 and 382-387 of 1974. The question that arises in all these petitions is the constitutional validity of the Taxation Laws (Extension to Union Territories) (Removal of Difficulties) Order 2 of 1970 issued under clause 7 of the Taxation Laws (Extension to Union Territories) Regular 1963 by which the Indian Income-tax Act war extended, with certain amendments, to the Union Territories of Goa, Deman and Diu with effect from April 1, 1963. Clause 7 of that Regulation, which is relevant for our purposes, reads as follows:

"7. If any difficulty arises in giving effect in any Union Territory to the visions of any Act, or of any rule, notification or order made or issued thereunder, the Central Government may, by general or special order published in the Official Gazette, make such provisions or give such directions as appear to it to be expedient or necessary for the removal of the difficulty."

2. Under the law in force in the former portuguese territories of Goa,