V.K. Gupta, C.J.

1. In this petition filed under Article 226 of the Constitution of India, the petitioner has challenged the order dated 20th April, 2000 passed by Respondent No. 5 in M.V. Revision No. 3 of 2000 whereby and where-under he has, while exercising his power under Section 27 of the Bihar Motor Vehicles Taxation Act, 1994 (1994 Act for short), dismissed the revision petitions filed by the writ- petitioner against the appellate orders passed by the appellate authority, namely, Secretary, Regional Transport Authority cum Deputy Transport Commissioner, Ranchi, on 18.12.1999.

2. The facts leading to the filing of this petition in brief are that the petitioner being a manufacturer of motor vehicles at its Plant in Jamshedpur has been claiming that it is not liable to pay tax under 1994 Act because the petitioner is not a dealer in motor vehicles as contemplated either under 1994 Act or under the Motor Vehicles Act, 1988 (1988 Act for short) and that in any eventuality, the liability of the petitioner to pay tax under 1994 Act would rest either under Section 7 (4) or Section 6 thereof and not under both the sections.

3. Before we proceed to examine the merits of the conte