This is a writ petition under Article 226 of the Constitution. The prayer contained in the petition is that a writ of certiorari may be issued quashing the order of the Sales Tax Officer dated 28th March, 1960, and of the Judge (Appeals) Sales Tax dated 27th July, 1961.

The facts giving rise to this writ petition are that the petitioner is a contractor who took a contract from the North Eastern Railway to build a certain number of passenger bogies for the railway. The underframes were to be supplied by the railway and the property in the frames was always to remain in the railway. The superstructure over these under-frames was to be constructed by the petitioner. The superstructure was to be raised according to certain specifications. The work was to be completed within a certain time and it was provided in the contract which is an annexure to the affidavit filed in support of the petition that the rate at which the contractor was to be paid for the work will be Rs. 50,200 for each bogie and an additional sum of Rs. 400 for extra work. The work to be done by the petitioner was to consist of "body construction including painting etc." It was provided that "the rate at which