JUDGMENT

PUNCHHI, J.— What is the ambit of the States claim to priority in relation to revenues, taxes, cesses and rates, due from a company in liquidation, is the question which stands posed in this appeal by certificate, granted by the High Court of Gujarat, in O.J. Appeal No. 2 of 1975. The question arises on the frame of Section 530(l)(a) of the Companies Act, 1956, as it stood at the relevant time, which is set out below:

"530. Preferential payments.- (1) In a winding up, there shall be paid in priority to all other debts -

(a) all revenues, taxes, cesses and rates due from the company to the Central or a State (Government or to a local authority at the relevant date as defined in clause (c) of sub-section (8), and having become due and payable within the twelve months next before that date;"

2. And sub-section (8)(c) of Section 530 says: "530.(8)(c) the expression the relevant date means

(i) in the case of a company ordered to be wound-up compulsorily, the date of appointment (or first appointment) of a provisional liquidator, or if no such appointment was made, the date of the winding-up order, unless in either case the company had commenced to be wound up voluntarily before tha