Ajit Singh Bains, J.

1. The petitioner-company is registered under the Companies Act, 1956 and its registered office is at Dhuri. It is doing the business of manufacturing sugar at Dhuri, District Sangrur. The petitioner-company purchased sugarcane from producers/growers at purchase centres and also at the mill premises for the purposes of manufacturing sugar. It is alleged in the petition that in the assessment year 1973-74, the petitioner-company has purchased sugarcane from producers directly. The petitioner-company filed its quarterly returns and also placed statements showing the purchases of sugarcane and sales of sugar. The Assessing Authority vide its assessment order dated 25th March, 1975 (annexure A) held that the petitioner-company was liable for purchase tax to the tune of Rs. 6,68,963.76. The petitioner-company submitted written arguments before the Assessing Authority that it was not liable but its arguments were rejected. It is against the assessment order dated 25th March, 1975 (annexure P-l) that the present writ petition has been filed.

2. Mr. Bhagirath Dass, the counsel for the petitioner, contends that the petitioner-company is not liable to pay the pur