( 1 ) EACH of these petitions under Art. 226 of the Constitution raises the same question. Since the facts, issues and questions of law raised are identical, these petitions are clubbed, heard together and disposed off by this common order.

( 2 ) THE reliefs sought in these petitions are mainly for a declaration to declare that Karnataka Industrial Area Development Board is a local area and the entry of scheduled goods into that area would not attract charging provisions under Entry Tax Act, since the Karnataka Ordinance No. 2 of 1992 which came into effect from 1-51992 having lapsed by efflux of time, the notifications issued pursuant to Section 3 (1) of the Act to effectuate the charge with respect to items coming under First Schedule to the Act having become inoperative, the notifications have been rendered redundant and non-operative, that the notification dated 30-7-1992 inserting Entry 81 which brought to effectuate the charge relating to Entry 80 of the First Schedule to the Act is beyond the competence of the Rule making authority. Apart from all this, the petitioners have questioned the correctness or otherwise of the pre-assessment notices, assessment orders framed by the assessing authorities for the assessment years 1992-93, 1993-94 and 1994-95.

( 3 ) THOUGH the point for decision is a simple one lying a very narrow compass, to reach it, one has to wade through various amendments, notifications and judicial pronouncements. To begin with we have the "principal Act," known as 'the Karnataka Tax on Entry of Goods Act, 1979' (the Act for short ). The Act is made to provide for the levy and collection of tax on the entry of certain goods into local areas in the State for consumption, use or sale therein, at rates not exceeding five percent of the value of the goods. The charging section under the Act is relatable to Entry 52 of List II of the seventh schedule which speaks of 'taxes on Entry of Goods into local area for consumption, use or sale therein'. Section 2 of the Act defines certain expressions occurring in the Act. Sub-section (5) defines 'local area' to mean, an area within the limits of the city under Karnataka Municipal Corporations Act, 1976, a municipality under the Karnataka Muncipalities Act, 1964, a notified area Committee, a Town Board, a Sanitary Board or a cantonment Board constituted or continued under any law for the time being in force and a mandal under the Karnataka -illa Parishads, Taluk Panchayat Samithi, Mandal Panchayats and Nyaya Panchayats Act, 1983. The Act received. the assent of the President on 27-5-1979 and published in the Karnataka Gazette on 1-6-1979. There were several amendments to it. By Act No. 12 of 1981, the date from which the Act was to come into force was shifted to 1-10-1980.

( 4 ) SECTION 3 in Chapter II of the Act is the charging section. Charging provisions as originally enacted provided for the levy of Entry tax under the Act on Entry of Schedule Goods into the local area. The local area for the purpose of levy was defined to mean only Municipal Corporations and Muncipalities. The levy of tax under this Act was only on three items mentioned in the Schedule appended to the Act. By subsequent notification the Act was extended to notified area committee, a town board, a sanitary board, a Cantonment Board, a mandal under Karnataka -illa Parishads, Taluk Panchayat Samithis, Mandal Panchayats and Nyaya Panchayats Act, 1983 and Panchayat area under Karnataka Panchayat Raj Act, 1993.

( 5 ) SOME of the petitioners in these petitions are traders, having their industries in Industrial area at Hosakote, Bangalore. The said area is developed and administered by the Karnataka Industrial Area Development Board as defined under the provisions contained in the Karnataka Development Act, 1966. Petitioner-industry causes entry of first schedule goods into the area of KIADB industrial area. The controversy between the parties to the lis is that since KIADB industrial area i