JUDGMENT

Dated this the 2^nd day of April, 2025.

Nitin Jamdar, C. J.

By this Appeal filed under Section 5 of the Kerala High Court Act , 1958, the Appellants – State authorities seek to challenge the judgment of the learned Single Judge directing the Appellants not to treat the property of the Respondent – Original Petitioner as “bought-in-land” and to drop all further proceedings in that regard.

2. The Appellants are the Tahasildar (Revenue Recovery), Vatakara, and the District Collector, Kozhikode. The Respondent – Original Petitioner, has been doing business in sandalwood oil.

3. The Petitioner was in arrears of a substantial amount of sales tax to ₹ the tune of 35,96,755/-. for the assessment years 1992-93 and 1993- 94. A demand for tax and penalty was raised. Two properties of the Petitioner were attached by Appellant No.1 and the Tahsildar, Kozhikode; one of them was 7.88 ½ acres of agricultural land. The Petitioner received a notice stating that the properties would be sold in an auction. Subsequently, a further notice was issued by the Sales Tax authorities. The Petitioner then sought relief under the amnesty scheme. The Petitioner was informed that the properties were already