Ranjan Gogoi, J.

1. The challenge projected being identical both the writ petitions were heard together and are being disposed of by this common judgment and order.

2. Both the writ petitioners are public sector undertakings engaged, inter alia, in the exploration of hydrocarbons from which the petitioners extract crude oil and natural gas. Crude oil and natural gas bearing land having been brought within the definition of "specified land" by the Assam Taxation (on Specified Lands) (Amendment) Act, 2004 and such land having been made exigible to payment of tax under the provisions of the principal Act, i.e., the Assam Taxation (on Specified Lands) Act, 1990, it is the validity of the aforesaid amendment Act that is the subject-matter of challenge in both the writ applications under consideration.

3. The Assam Taxation (on Specified Lands) Act, 1990 was enacted by the State Legislature of Assam with a view to providing additional revenue to the State by imposing a tax on certain categories of land. The Act, as originally enacted, defines specified lands to mean any land used or intended to be used for growing tea and for purposes ancillary thereto as well as any land held for t