( 1 ) A large number of writ petitions have been moved by a number of banks challenging the notices issued by the Commercial Tax Officer, Central Section, Calcutta under Section 14 (1) of the Bengal Finance (Sales Tax) Act, 1941 hereinafter described as the Act. Identical notices dated 13th December, 1985 were sent to a number of banks alleging that the banks were "engaged in the business of letting out of movable property, viz. , bank lockers on hire/lease/rentals to others for cash, deferred payment or other valuable consideration". It was alleged that such transfer of right to use the bank locker amounted to "sale" with effect from 1st April, 1984. The banks were called upon to produce documents and/or statements relating to receipts on account of rent of lockers of different branches of the banks in West Bengal from 1st April, 1984 for the purpose of levy of sales tax under the Act. The words "taxes on the sale or purchase of the goods other than newspapers" can be levied by the State Legislature by virtue of entry 64 of List II of the Seventh Schedule to the Constitution. By the Constitution (46th Amendment) Act, 1982, Article 366 which the definition cl