PADMANABHAN, J.

These writ petitions arise under the Tamil Nadu General Sales Tax Act and involve a common question of law.

I shall confine myself to W.P. No. 4389 of 1977 for a narration of the statement of facts. The petitioner is a firm carrying on business in pulses, grams and gram dhal under the name and style of M/s. S. K. Nataraja Mudaliar and Co., and is an assessee under the Tamil Nadu General Sales Tax Act.

Section 14 of the Central Sales Tax Act, 1956, declares certain goods to be of special importance in inter-State trade or commerce and section 15 imposes conditions and restrictions subject to which the state Government can impose tax on the internal trade in those goods, the main condition being that no State shall have a system of levy other than a single point levy, at a single stage to be specified by law. Section 14 was amended by Central Tax Act No. 103 of 1976 and in the items included in section 14, item (vi-a) was introduced. Item (vi-a) reads thus :

"(vi-a) pulses, that is to say, -

(i) gram or gulab gram (Cicerarietinum L.);

(ii) tur or arhar (Cajanus cajan);

(iii) moong or green gram (Phaselous aureus)."

Section 15 of the Central Sales Tax Act reads as follows :

" Every sales tax law of a State shall, in so far as it imposes or authorises the imposition of a tax on the sale or purchase of declared goods, be subject to the following restrictions and conditions, namely :-

(a) the tax payable under the law in respect of any sale or purchase of such goods inside the State shall not exceed four per cent of the sale or purchase price thereof, and such tax shall not be levied at more than one stage;

(b) where a tax has been levied under that tax in respect of the sale or purchase inside the State of any declared goods and such goods are sold in the course of inter-State trade or commerce, and tax has been paid under this Act in respect of the sale of such goods goods in the course of inter-State trade or commerce, the tax levied under such law shall be reimbursed to the person making such sale in the course of inter-State trade or commerce in such manner and subject to such conditions as may be provided in any law in force in that State :(c) where a tax has been levied under the law in respect of the sale or purchase inside the State of any paddy referred to in sub-clause (i) of clause (i) of section 14, the tax leviable on rice procured out of such paddy shall be reduced by the amount of tax levied on such paddy;

(d) each of the pulses referred to in clause (via) of section 14, whether whole or separated, and whether with or without husk, shall be treated as a single commodity for the purposes of levy of tax under that law." *

The clauses (c) and (d) to section 15 were introduced by the amending Act 103 of 1976. A reading of sections 14 and 15 of the Central Sales Tax Act, makes it clear that in the case of declared goods as enumerated in section 14, the State shall not levy more than 4 per cent tax on the sale or purchase price. Further such tax shall not be levied at more than one stage. Section 15(d) as amended by amending Act No. 103 of 1976 makes it clear that the pulses catalogued in clause (vi-a) of section 14 whether whole or separated and whether with or without husk, shall be treated as a single commodity for the purpose of levy of tax under the Central Sales Tax Act. It has to be noted here, that for the first time pulses were brought under the category of declared goods in section 14 of the Central Sales Tax Act. After the inclusion of pulses in the list of declared goods by amending Act 103 of 1976, the State Government would not be entitled to levy tax at more than 4 per cent on the sale or purchase of pulses.

While so, for the assessment year 1977-78, the assessee filed his monthly A-2 return for the period April, 1977, to October, 1977, and paid the tax on the turnover at 4 per cent. The second respondent by his communication dated 7th December, 1977, called upon the petitioner to pay an addit