Dixit, C.J.

By this application under Article 226 of the Constitution of India, the petitioner Company prays for the issue of an appropriate writ or direction restraining the opponents from making any assessment under the Indian Income Tax Act and from levying or collecting Income Tax from the Company for a period of twelve years from June 1949 in respect of income of the Weaving Division and for a period of twelve years from February 1954 in respect of the income of the Staple Fibre Section of the petitioner-Company.

The events leading to the supplicant's claim for exemption from taxation are that in order to promote the industrial development of the former Gwalior State and to facilitate the establishment of certain industries in the State, the Maharaja of Gwalior on the recommendation of his Minister for Industries, Commerce and Communications, made an order on 18-1-1947 exempting from any form of taxation for a period of twelve years the income of certain industries and factories which M/s. Birla Bros., Ltd., Gwalior, intended to establish in Gwalior State. Consequent to this order of the Ruler, an agreement was entered into between the Gwalior Government and M/s. Birla