DHAVAN, J. : This is an application by Seth Sheo Prasad under clauses (a), (b) and (c) of Art. 133(1) of the Constitution for a certificate enabling him to appeal to the Supreme Court from a decision of this Court rejecting his appeal from an order of Oak, J. dismissing his petition under Art. 226 and refusing to restrain the State of Uttar Pradesh, the Sales Tax Officer, Hathras and the Collector of Aligarh from recovering from him a certain amount of sales tax assessed on the firm of which the petitioner was a partner. The facts are these : Messrs. Lallamal Harden Das Cotton Spinning Mills Company was a partnership firm consisting of the partners including the petitioner Seth Sheo Prasad. It owned a cotton spinning mill in Hathras and carried on the business of producing and selling cotton yarn. In 1944 differences arose between the partners and one of them Raghunath Prasad, filed a suit for the dissolution of the partnership. This suit was dismissed on a preliminary ground and an appeal from it is decision was filed in this Court. During the pendency of this appeal, receivers were appointed for working the mills under the directions of the Court. In 1949 the receiver re