V.V.S.Rao, J.

PART - I

INTRODUCTION

The challenge in these writ petitions is to the Andhra Pradesh Tax on Entry of Motor Vehicles into Local Areas Act, 1996 (A.P.Act No.26 of 1996) (the Act, for brevity). Though the attack is against the constitutional vires of charging Section 3 of the Act, without which the other provisions cannot survive, the entire Act may have to suffer invalidation if the petitioners succeed in these cases.

THE BACKGROUND

The following background of these cases is taken from W.P.Nos.1564 of 2009, 6713 of 2010 and 2348 of 2011.

(A) W.P.No.1564 of 2009

The petitioner, a company having its registered office at Hyderabad is engaged in the business of civil contracts, consulting and engineering. They are registered dealers under the Andhra Pradesh Value Added Tax Act, 2005 (the VAT Act, for brevity) on the rolls of the Commercial Tax Officer, Jubilee Hills Circle. M/s.Patel Soma JV awarded them works contract of left main canal of Polavaram Project and Hiramandalam Reservoir of Vamsadhara Project. The contract inter alia includes excavation, lining the canal and construction of CM and CD works. For these works, the petitioner purchased three wheel lo