1. The petitioner-Company was assessed to sales-tax under S.35 of the Bombay Sales Tax Act, 1959, for the year 1972-73 by Ext. P4 dated 13-3-1975. A penalty was imposed upon it under Ext. P5 dated 13 81975. A notice of demand was served on it by the 3rd respondent, Deputy Tahsildar, Mattancherry, Cochin, under S.7 of the Kerala Revenue Recovery Act. These orders are challenged by the petitioner.

2. Counsel for the petitioner, Shri Chakkappan Kalliath, submits that Ext. P4 levying sales-tax in respect of the sales in question is null and void as such levy is barred under Art.286 of the Constitution. Consequently Ext. P5 imposing penalty upon the petitioner is also null and void. Counsel further submits that the notice issued under S.7 by the 3rd respondent Deputy Tahsildar is invalid as he is not a competent officer to initiate proceedings for collection of revenue due and payable to the Collector of Bombay. Counsel also submits that the provisions of either the Kerala Revenue Recovery Act, 1968, or the Revenue Recovery Act, 1890, do not authorise collection of revenue in one State on behalf of the authorities of another State.

3. The contention that Exts P4 and P5 are nul