( 1 ) THIS is an application under Article 228 of the Constitution or the issue of a writ of certiorari for quashing three re-assessment orders under Section 19 of the Madhya Pradesh General Sales Tax Act, 1958, in respect of three years from 1957 to 1960, imposing a total amount of Rs. 23,1 4. 19 np. as tax and penalty on the petitioner.

( 2 ) THE petitioner was in the normal course assessed to sales tax for three years included in the period from 24th October, 1957 to 19th October, 1960. On 17th October, 1961 three notices in respect of the three accounting years stated above were issued to the petitioner under Section 19 of the Act for escaped assessment. The notices directed the petitioner to appear before the Sales Tax Officer with account-books for the period. It was mentioned in the notices that they had been issued on the basis of a report made by Shri Ghai, the Sales Tax Inspector. It appears that on 10th October, 1961, the Sales Tax inspector paid a visit to the shop of the petitioner for checking the account-books. During this checking the Inspector discovered that the applicant had maintained two sets of account-books for the three material years which indi