1 The respective petitioners, in these writ petitions, challenge the orders of assessment passed by the concerned Sales Tax Officers, making them liable for payment of sales tax under the General Sales Tax Act, 1125, as the last purchaser of the commodity, in question, in the State. Their contention is that the imposition of a levy, in the circumstances, on the last purchase in the State, offends Art.301 of the Constitution and is not saved by Art.304(b) of the Constitution. There are no doubt certain other questions arising for decision in these writ petitions. But the common question that arises is regarding the attack on these assessments, based upon Art.301 and 304(b) of the Constitution; and I have heard arguments only on that aspect at present.

2 As Mr. K. V. Surianarayana Iyer, learned counsel appearing for the petitioners, who are the same in both O. P. Nos. 3210/61 and 261/62 has advanced the leading arguments on this aspect, I will refer in the first instance, to the averments made in the affidavit filed in support of O. P. No. 3210 of 1961, in so far as they are relevant to this aspect.

3 The petitioner therein, which is a partnership, having its Head Office in Bombay and