ORDER

1. The Challenge in this appeal arises out of the decision of the High Court relating to eight show-cause notices issued by the appellants under the provisions of the Uttar Pradesh Trade Tax Act, 1948 (hereinafter referred to as "the Act"). The eight show-cause notices were issued for the period 1982-83 to 1984-85. By the show-cause notices the respondents were asked to explain why they should not be held liable for payment of sales tax on account of sales made by them for the period covered by the notices.

2. The respondents manufacture glass bangles. Although there is some dispute as to when the respondents commenced their business, there is no dispute, and the High Court has found that the respondents continued to realise sales tax on their products from their customers until they were granted an eligibility certificate under Section 4-A of the Act on 23-10-1984.

3. The respondents submitted their reply to the show-cause notices on 2312-1985 and on 26-12-1985 an order of assessment was passed in respect of the eight show-cause notices raising a demand against the respondents.

4. The respondents filed a writ petition challenging the show-cause notices on 2-1-1986. During th