A.N.Bhandari, J.

1. This petition under Article 226 of the Constitution raises the question whether the Excise and Taxation Officer was justified in requiring the petitioner to pay a sum of Rs. 1,59,762-12-0 by way of sales tax.

2. The petitioner in the present case is the Indian Iron and Steel Company, Limited, which has its head office at Calcutta and two branches known as Burnpur Works and Kulti Works.

3. On the 7th January, 1954, the petitioner applied to the Excise and Taxation Officer, Ambala, for registration under the Punjab General Sales Tax Act, 1948 , without prejudice to its contention that it did not carry on any business in the Punjab and was not a dealer within the meaning of the said Act. A registration certificate was issued to him in due course.

4. On the 25th August, 1956, the Assessing Authority, Punjab, came to the conclusion that the taxable turnover of the petitioner for the year 1953-54 was Rs. 51, 12,408 and that the sales tax payable by the petitioner was Rs. 1,59,762-12-0. The petitioner presented an application before the Deputy Excise and Taxation Commissioner, Jullundur, for permission to prefer an appeal against the order of assessment without