( 1 ) A very interesting question of law has been raised and ably argued in this case, namely, whether the Certificate Officer who has issued the certificate of which a copy is annexed to the petition (annexure 'a') has jurisdiction to issue the certificate in question to recover the arrears of sales tax and penalty due from the petitioner for the four quarters ending Chaitra 1365 B. S. , in view of the fact that the business in respect of which the sales tax was assessed is being carried on within the limits of the Presidency town of Calcutta and the assets of the certificate-debtor are also situated within that town, the certificate office being a certificate office of the District 24-Parganas, which, for administrative purposes, does not include the Presidency town of Calcutta. The manner in which dues under the Bengal Finance (Sales Tax) Act of 1941 have come to be realised by the certificate procedure is as follows : Section 11 (4) of the Sales Tax Act provides-'"any amount of tax or penalty which remains unpaid after the date specified in the said notice shall be recoverable as an arrear of land revenue as if it were payable to the Collector. . . " It is contende