J.M.Tandon, J.

1. The petitioner is engaged in the business of extracting oil from rice bran. The rice bran is the outer covering of the rice grain which stands peeled off during rice polishing. The rice bran is mixed with a chemical known as hexene for the purpose of extracting oil. The State Government issued notification dated 11th January, 1979 (P. 6), regarding sales tax payable in respect of the sale of edible oils and it reads :

No. S. 0. 1/C.A. 74/56IS. 8/EI79.

Whereas the Government of Punjab is satisfied that it is necessary in the public interest so to do;

Now, therefore, in exercise of the powers conferred by Sub-section (5) of Section 8 of the Central Sales Tax Act, 1956 (Central Act 74 of 1956), and all other powers enabling him in this behalf, the Governor of Punjab is pleased to direct that the tax payable by any dealer having his place of business in the State of Punjab in respect of the sales made by him, of edible oils from any such place in the course of inter-State trade or commerce to any registered dealer having his place of business in any other State or Union Territory of India, shall be calculated at the rate of one per cent of his turnover in so f