1. The petitioner, a public limited company incorporated under the Companies Act, while questioning correctness of the order dated 21.3.2014, passed by Commercial Taxes Officer, Anti Evasion Circle, Bhilwara, has also challenged constitutional validity of Sections 26 and 82(3) of the Value Added Tax Act, 2003 (hereinafter referred t o as 'the VAT Act').

2. The factual matrix deserve notice is that the Government of Rajasthan, exercising authority under sub section (5) of Section 8 of the Central Sales Tax Act, 1956 (hereinafter referred to as 'the CST Act'), with a view to increase inter-State sales and decrease the quantum of branch transfers in order to augment the State's revenue from inter-State sales, issued a partial exemption notification dated 6.5.1986. The notification aforesaid reads as under:-

“NOTIFICATION NO.F.4(72)FDGr.IV/8I-18 Dated 6/5/1986 -

S.O.23.-In exercise of the powers conferred by S.8(5), CST Act, 1956, the State Govt. in supersession of the FD notfn. No.F4(72) FDGr/IV/81-36 dated 3.12.1985 [S.No. 584], hereby directs that, with immediate effect, any dealer, having his place of business and manufacturing goods in the State of Rajasthan, may claim partial