SYED SHAH MOHAMMED QUADRI, J.

( 1 ) THE question that arises for consideration in these wrih petitions is. whether the petitioners, manufacturers and/or dealers of cement, are liable to pay arrears of difference in sales tax for the period during which the concessional rate of sales-tax granted by the Government was in force .

( 2 ) TO appreciate this question, the relevant facts may be noticed. Under the andhra Pradesh General Sales Tax Act (for short "the State Act") as well as the central Sales Tax Act (for short "the Central Act") cement is taxable. The Government of Andhra Pradesh in exercise of their power under Section 9 of the state Act granted reduction in the rate of sales tax to the manufacturers of cement in Andhra Pradesh by issuing three orders. IB G. O. Ms. No. 76, dated 24-1-1987 rateof sales tax was reduced to4% on cement sold to Government and government companies. In G. O. Ms. No. 77, dated 24-1-1987 the rate of sales tax was reduced to 4% on cement sold to manufacturers of cement products. In g. O. Ms. No. 78, dated-24-1-1987 the rate of sales tax under the Central Act was reduced to 2% on inter-State sales of cement whether or not the returns were accompanied

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