( 1 ) THESE two writ petitions alongwith connected and similar writ petitions are being disposed off by a common judgment.

( 2 ) HEARD Shri Bharatji Agarwal, Senior advocate, Sri Piyush Agarwal, Advocate, and other learned counsel for the petitioners, and shri S. P. Gupta, Senior Advocate and learned standing Counsel for the respondents.

( 3 ) BY means of this writ petition the petitioners are challenging the constitutional validity of the U. P. Tax on Entry of Goods act, 2000 (hereinafter referred to as the Act)on the ground inter alia that it is violative of articles 301 and 304 of the Constitution of india.

( 4 ) THE petitioner No. 1 in writ petition no. 251 of 2003 is a public sector corporation, being a Government of India undertaking. It has various units in the country, but in this case we are only concerned with its refinery unit at Mathura where the petitioner is manufacturing various petroleum products which are sold by the petitioner within and outside the State of U. P. The refinery of the petitioner situate at Mathura purchases crude oil from different Gulf countries from abroad. This crude oil which is coming from outside the country within the local area