Ashwini Kumar Sinha, J.

1. These three writ cases involve common question of law and hence they have been heard together and are being disposed of by a common judgment.

2. The authority concerned, i.e., respondent No. 2, has held that the petitioners were liable to pay sales tax on wheat bran (chokar).

3. Whether wheat bran (chokar) is a cattle feed or not and whether the petitioners are liable to pay sales tax on the sale of wheat bran are the intricate and significant questions involved in these writ cases.

4. Admittedly the period in question is the period before 29th June, 1985 (the date on which Notification No. S.O. 611 dated 29th June, 1985, came into force).

5. The petitioners claim that no sales tax was payable on the sales of wheat bran as, according to the petitioners, it was exempted under item No. 35 of the Notification No. Bikrikar/San/1026/77-14547 dated 26th December, 1977 (annexure 1 to C.W.J.C. No. 2725 of 1984), as a cattle feed; whereas, in short, the submission advanced on behalf of the State is that the effect of exemption notification dated 26th December, 1977, is taken away because a retroactive notification (with effect from 26th December, 1977) was