Sreedevi, J.

Appellants in the above appeals who are the petitioners in the writ petitions raised three questions for adjudication. The first question is whether the excavators and road rollers are motor vehicles under S.2(28) of the Motor Vehicles Act (hereinafter referred to as the M.V. act), (2) whether the Registering authorities can insist on payment of entry tax as a condition precedent for registering the said vehicles and (3) whether the Central Sales Tax paid can be deducted under S.4(2) of the Kerala Taxation on Entry of the Motor Vehicles into Local areas Act (hereinafter referred to as the Entry Tax act).

2. The learned single judge heard the above writ petitions and passed the impugned common judgment whereby the first two questions were answered against the petitioners. The learned judge held that the excavators and road rollers are motor vehicles and as such they are liable to be taxed as per the Entry Tax Act, that the amount paid as Central Sales Tax by any of the petitioners for purchase of the vehicles is liable to be deducted from the amount which they are liable to pay under the Entry Tax Act. The petitioners were directed to pay the entry tax within