JUDGMENT

K. JAYACHANDRA REDDY, J.:- The petitioner-Company is engaged in the business of manufacture of aluminium products and its factory is located at Kalwa in Thane District (Maharashtra). The Company obtains aluminium as raw materials for consumption from another factory of theirs situated in a different State. With effect from 1-10-82 the Company at Kalwa was included in the municipal jurisdiction of Thane. Prior to that date the factory was not within the jurisdiction of Thane Municipality and did not have to pay any octroi on the raw materials brought into its factory at Kalwa. By a Notification dated 23-8-82, the Government of the City of Thane and Kalwa was brought within the jurisdiction of the Thane Municipal Corporation, the respondent herein and all goods imported into the area of the Thane Municipal Corporation were subjected to octroi at the rates mentioned in Schedule 1 to the Maharashtra Municipalities (Octroi) Rules, 1968 (Rules for short). Schedule 1 to the said Rules contains description of various goods and articles which were liable to octroi and minimum and maximum rates are prescribed. Item No. 77 in the said Schedule 1 to the said Rules covered non-ferrous m