N.K.Agrawal, J.

1. These are two petitions (Civil Writ Petition Nos. 3542 and 7379 of 1997) Under Articles 226 and 227 of the Constitution, both by DLF Industries Limited, challenging the vires of certain provisions of the Haryana General Sales Tax Act, 1973 (for short, "the Act") and for quashing the assessment orders relating to 1990-91 and 1992-93 and also consequential demand notices. The vires and constitutionality of the proviso to Section 6(1), proviso to Section 18 of the Act and validity of Rule 24(i) and Rule 39A(11) of the Haryana General Sales Tax Rules, 1975 (for short, "the Rules") are under challenge.

2. Assessment was made by the Assessing Authority for the year 1990-91 on January 11, 1994 and for the year 1992-93 on January 28, 1997. The petitioner is a public limited company incorporated under the Companies Act, 1956 . DLF Universal Limited is the holding company of the petitioner-company. The said holding company was engaged in the work of colonization in the State of Haryana and carried out works contracts. Major part of the work was done by the holding company by entering into contracts with the petitioner-company. The holding company thus became the co