JAWAHAR LAL GUPTA, J. - The petitioners in these 16 writ petitions are dealing in grinding of cotton-seeds and sale of cotton-seed oil. They were assessed for the payment of sales tax on the hypothesis that they were producing edible oil. These assessments were later on suo motu reopened by the Regional Authority under the Punjab General Sales Tax Act, 1948. Separate notices were issued in respect of different assessment years. C.W.P. Nos. 264, 311 - 315, 1302, 6919, 1673, 2011, 2084 and 6769 of 1987, 2476, 8407, 8408 and 8409 of 1988 are directed against the notices served on the respective petitioners. In C.W.P. No. 6919 of 1987, the petitioner appeared before the Assistant Excise and Taxation Commissioner and pursued the remedies under the Act. In this petition, the orders at annexures P4 and P5 passed by the respective authorities have been challenged. It would be trite to notice the facts as stated in C.W.P. No. 6919 of 1987.

The petitioner is a partnership firm at Mansa. It is engaged in grinding of cotton-seeds, etc. The cotton-seed oil is sold in the State of Punjab as well as in other States. It is registered as a dealer under the Punjab General Sales Tax Act, 194