( 1 ) IN this third round of litigation with the sales Tax authorities, by this petition under Article 226 of the Constitution of India, the petitioner seeks to challenge the order, dated 20 March 2001, passed by the Deputy Collector (Recovery )/collector, Sales Tax, new Delhi, holding the petitioner company to be the transferee company, liable to pay the outstanding sales tax dues of the transferor company, namely M/s. Byford leasing Limited, hereinafter referred as the Byford, in terms of Section 32 of the Delhi Sales Tax Act, 1975 (for short the. Act) and having defaulted in discharging the said liability, liable to be proceeded against under Section 139 of the Delhi Land Reforms Act, 1954 (for short the Land Reforms Act ).

( 2 ) IN order to appreciate the controversy involved, we shall briefly notice the material facts, which are as follows:

THE first petitioner is a company incorporated on 9 March 1998 with the main object of carrying on the business of collection, processing and disposal of solid municipal waste etc. The second petitioner is one of the directors of the company. On 28 September 2000 the petitioner received a copy of the notice under Section 139 of the