JUDGMENT :

SONIA GOKANI, J.

1. The petitioner is seeking to challenge, by way of the present petition under Article 226 of the Constitution of India, the action of the authority, where his vehicle is consequently detained for the second time after its release on collecting the tax, penalty, etc. within one day.

2. Brief facts, leading to the present petition, are as follows:

The petitioner is the owner of Omni bus contract carriages bearing registration No.RJ 51PA 5494 and is covered with valid All India Permit. The petitioner also had paid tax of Rs.60,000/- at the quarterly rate valid for entire country.

The respondent vide its challan no.GJ6587220312213716 seized and detained the said vehicle on 12/03/2022. The bus was having 33 sleepers and 8 sitting capacity at the time of its permission. The said aspect is also noted in the permit granted to him in respect of All India Tourist Permit (Bus)- Non Air-Conditioner.

3. It is averred by the petitioner that the respondent has demanded a tax for the period from April, 2021 to March, 2022 of Rs.4,88,760/-, penalty of Rs.2,86,325/- and i