Hon’ble Manoj Kumar Gupta, J.—These petitions filed under Article 226 of the Constitution call into question the vires of the Uttar Pradesh Tax on Entry of Goods into Local Areas Act, 2007 (the Act). The petitions have been filed on basis of liberty granted by the Supreme Court by order dated 21 March 2017, while disposing of a batch of Civil Appeals and other connected matters, the leading case being Civil Appeal Nos. 997-998 of 2004 by State of U.P. and others against M/s. Indian Oil Corporation Ltd. The judgement opens by noticing that the theory of compensatory tax propounded in Seven Judges’ Bench judgement in Automobile Transport (Rajasthan) Ltd. etc. v. State of Rajasthan and others, 1963(1) SCR 491, being doubted by a Bench of two Hon’ble Judges of the Supreme Court in Jai Prakash Associates Ltd. v. State of M.P. and others, (2009) 7 SCC 339, the matter was placed before a Nine Judges’ Bench. The Nine Judges’ Bench, in Jindal Stainless Ltd and another v. State of Haryana and others, 2016 (11) Scale 1, (for short “Jindal Stainless-II” or “Nine Judges’”), while answering all major constitutional and legal issues, left open three issues for decision by regular benches