J.N.Bhatt, J.

1. By this writ petition, by invocation of the provisions of Art. 226 of the Constitution of India, the petitioner, M/s Indian Oil Corporation (In short "IOC"), a company incorporated under the provisions of the Companies Act, 1956 , and as such, a Central Government undertaking, has knocked the doors of justice on account of alleged illegal imposition of tax by an assessment order, dated, 14.4.1999, which came to be confirmed by the appellate authority, by order dated 12.5.2000, as well as, by an order in a revision, dated 4.3.2005 (unsuccessful petitioner at three stages), raising the following points in focus:

Whether the Commercial Taxes Tribunal, Patna, confirming the imposition of levy of sales tax on the export sale made by the petitioner to Nepal, is required to be intercepted or Injected by an interlocutory order, until disposal of the petition on full fledged hearing on merits being unauthoised, illegal and without sanction of law?

2. With a view to appreciate the sole controversy, at this juncture, whether the interlocutory relief staying the operation of the assessment order, confirmed by the appellate authority and later on, by Tribunal is justifi