( 1 ) BY this application under Article 226 of the Constitution, the petitioner Straw products Ltd. a public company incorporated in the former State of Bhopal, prays that the Taxation Laws (Merged States) (Removal of Difficulties. Amendment order, 1962, be declared ultra vires, inoperative and of no effect whatsoever, and seeks a writ of certiorari for quashing assessments of income-tax made on it on 43-1958 for the years 1952-53 and 1953-54, as also the assessments made for the assessment years 1954-55 to 1960-61. The petitioner also seeks a direction restraining the respondents from proceeding with the assessments for the assessment years 1961-62 to 1965-66.

( 2 ) THE matter arises thus. The petitioner is a public limited company engaged in the manufacture of straw-boards and other allied products. It was incorporated in the quondam State of Bhopal in 1938. Under an agreement concluded between the company and the Government of the Bhopal State, the Company was exempted from payment of "any sum by way of taxation to the State" for a period of ten years from the date on which it took over the land granted to it by the State for business purposes. This agreement was ac