JUDGMENT

CHANDRACHUD, CJI.:—These are two appeals from Uttar Pradesh involving validity of a levy which bears the somewhat unusual name of Circumstances and Property Tax. Civil Appeal 1528 of 1970 is by Certificate granted by the Allahabad High Court under Articles 132 (1) and 133 (1) (c) of the Constitution while Civil Appeal 564 of 1973, is by Special Leave granted by this Court.

2. The facts leading to Civil Appeal 1528 of 1970, are as follows :-

The appellant M/s. R. R. Engineering Company is a partnership firm engaged in the business of manufacture and sale of machinery, machine tools and as structural engineering. Its registered office is situated at Clutterbuckganj which was at one time within the local limits of the jurisdiction of the District Board of Bareilly. Acting under the power conferred by Section 109 of the District Board Boards Act, 1923, the District Board, Bareilly, by Resolution No. 3 dated February 18, 1923, decided to impose the Circumstances and Property Tax on persons according to their circumstances and property. Rule 7 framed under Section 172 of the Act for assessment and collection of the said tax-was published on March 10, 1928, providing for the maximu