K. Shivashankar Bhat, J.—The first respondent in each of these appeals is the petitioner who filed the writ petitions. In the writ petitions, two letters dated February 22, 1988, and October 11, 1988, addressed by the Reserve Bank to all the exporters/importers in the Goa Region were sought to be quashed; by those letters, it was pointed out that demurrage charges payable to the overseas owners of vessels chartered by the Indian parties attract Income Tax and hence application for remittances towards them are to be duly supported by Income Tax clearance certificates; it was further clarified that "all demurrage amounts payable in respect of foreign vessels chartered for carriage of goods exported from India under any type of contract, i.e., C. & F/CIF/FOB attract India Income Tax and, therefore, the exporters/importers were advised "to ensure that all applications for remittances towards demurrage payable on foreign vessels to overseas parties are duly supported by Income Tax clearance certificates or documentary evidence that tax is withheld along with a no objection certificate from the Income Tax authorities." These letters were allegedly the result of an opinion express