The judgment of the Court was delivered by

OAK, C.J. - This petition under Article 226 of the Constitution arises out of recovery proceedings under the Central Sales Tax Act and the U.P. Sales Tax Act, hereinafter referred to as the Central Act and the U.P. Act respectively. M/s. Beni Ram Mool Chand are the petitioners.

This is a firm carrying on the business of manufacturing and selling scents. The petitioner became liable to pay sales tax under the two statutes. The tax remained unpaid for a considerable time. The authorities, therefore, initiated proceedings for recovery of arrears of tax. The Collector of Farrukhabad issued on 28th March, 1967, a sale proclamation with respect to certain property belonging to the petitioner. According to the sale proclamation, the arrears outstanding against the petitioner amounted to Rs. 73,000 and odd. According to the petitioner, the claim of the respondents is highly exaggerated. The petitioner has, therefore, flied this petition for having the sale proclamation quashed. Annexure F to the petition is a copy of the sale proclamation.

According to the respondents, the petitioner became liable to pay interest on arrears under sub-sect