The petitioner seeks to quash the recovery notice issued by the third respondent dated 28.08.1996 and further direct the respondents to give effect to the judgment of the Supreme Court in the case of Vikas Sales Corporation v. Commissioner of Commercial Taxes, (1996) 102 STC 106 with effect from 01.05.1996.

2. The petitioner is a manufacturer and exporter of leather and an assessee on the file of the third respondent. The petitioners assessment for the assessment years 1989-90 to 1994-95 were finalised by the third respondent resulting in the balance of arrears of Rs.70,40,425/- due from it. Out of the above said arrears, the petitioner paid a sum of Rs.1,22,663/- towards tax involved of sales of other goods purchased from unregistered dealers and also sales of assets. The balance arrears amounting to Rs.69,17,861/-represented the premium received on the sale of REP licence as the petitioner failed to pay the arrears. The third respondent issued recovery notice, which is challenged in this writ petition.

3. It could be seen from the records that the arrears accrued on account of separate assessment/revision of assessment passed by the third respondent for each assessm