This appeal is directed against the judg­ment and order dated 23rd February, 2000 passed by the learned Single Judge in Civil Rule No. 1667/1989 (Guwahati), which was renumbered as Civil Rule No.143/1991 (Imphal), whereby and whereunder the writ petition filed by the appellant challenging the notice of demand dated 27th July, 1989 for Rs.71,21,27,675/- (Rupees Seventy One Crores Twenty One Lakhs Twenty Seven Thousands Six Hundred Seventy Five) issued by the Chief Engineer, Electricity Department of Government of Manipur, towards the sales tax payable under the provisions of the Manipur Tax on Sale of Electricity Act, 1984 (in short," 1984 Act") has been partly allowed while refusing to set aside the said demand notice.

2. The appellant filed the said writ petition contending inter alia that the Government of India issued the Office Memorandum requir­ing the appellant to supply the electricity gen­erated by it in Loktak Hydro Electric Power Project in the State of Manipur to all the States in the North Eastern Region, as per require­ment and thereafter, in view of the subsequent decision of the Ministry of Energy, Govern­ment of India taken on 13th November, 1990 al