Judgment

KANIA, J. :- These writ petitions are filed by Public Limited Companies growing and manufacturing tea in the States of West Bengal and Kerala respectively. Although, there are some differences in the facts, the material facts are largely common and the questions raised in the petitions can be fairly regarded as common questions of law. They are, therefore, being disposed of together by this common judgment.

2. The petitioners in Civil Writ Petitions Nos. 5409- 10 of 1980 are the Tata Tea Limited and a shareholder of the said Company. These petitions are directed against the State of a West Bengal, Commissioner of Agricultural Income-tax of West Bengal, West Bengal Agricultural Income-tax Officer, Calcutta Range-I, Union of India and Income-tax Officer, O-Ward, Companies District-II, Calcutta. The petitioners in Civil Writ Petitions Nos. 5411-12 of 1980 are also the Tata Tea Limited and a shareholder thereof. The respondents are State of Kerala, Commissioner and Assistant Commissioner of Agricultural Income-tax at Kerala, Union of India and the concerned Income-tax Officer. The petitioners in other writ petitions are Tea Companies and shareholders thereof and the respondents