D.V. Shylendra Kumar, J.

1. Writ petitioners are all persons who come within the definition of 'assessee' as defined under Section 2(1)(a) of the Karnataka Special Tax on Entry of Certain Goods Act, 2004 [Karnataka Act No. 29 of 2004] [for short, the Act], who are complaining of the liability for payment of tax created in terms of the charging Section - Section 3 - of the Act, which reads as under:

3. Levy and collection of tax- (1) Subject to other provisions of this Act, there shall be levied and collected a tax on the entry of any notified goods into any local area for consumption, use or sale therein, on the value of the notified goods at the rate specified in respect of such goods under the Karnataka Sales Tax Act.

(2) The tax shall be payable by an importer in accordance with the provisions of this Act or the rules made thereunder.

to be a tax levied by the Karnataka State in violation of the provisions of Part-XIII of the Constitution of India; that the levy of such a tax directly on goods brought from outside the state and when it enters any local area is in the nature of a restriction or curb placed on the inter-state movement of goods in violation of the mandate of Artic