This petition filed by the petitioner-a Govt. of India Undertaking owned and controlled by the Central Government through the Ministry of Petroleum and Natural Gases, Govt. of India and engaged in the business of manufacture, sale and distribution of motor spirit, diesel oil and other petroleum products all over the country including the State of U. P.- raises a short but an interest ing question.

2. Charging Section 3 of the U. P. Sales of Motor Spirit, Diesel Oil and Alcohol Taxation Act, 1939 (briefly, the Parent Act) states that the tax on retail sales of motor spirit and diesel oil shall be paid at such rate as may be notified not exceeding 9 paise in the case of motor spirit and 7 paise in the case of diesel oil per litter on such sales. The petitioner admittedly, a dealer is liable to pay tax on the sales of motor spirit and diesel oil. Section 3 of the Parent Act was so amended by Section 2 of the U. P. Sales of Motor Spirit, Diesel Oil and Alcohol Taxation (Amendment) Act, 1994 (hereinafter referred to as the Amending Act) as to sub stitute the words "fourteen percent" in clause (a) of Section 3 (1) for the words "ten percent" and the words "sixteen percent"