J U D G M E N T

Harisankar V. Menon, J The appellant is stated to be engaged in the business of manufacturing and distribution of plywood and having branches across the country, including one at Kariakal, Puducherry. The appellant had purchased a car and got it registered in Puducherry, as evidenced by Ext.P2 registration certificate. The appellant states that Ext.P6 demand notice was issued by the 2^nd respondent directing payment of tax under the Kerala Motor Vehicles Taxation Act , 1976, even when there was no permanent use of the vehicle in Kerala. In response to the notice, a reply was filed as evidenced by Ext.P7 and pursuant to the directions of this Court in W.P(C) No.14657 of 2018 dated 27.04.2018, the 2^nd respondent considered the issue coming out with Ext.P8 notice dated 28.06.2018, directing payment of Rs.15,37,660/- towards tax. This is followed by the recovery notices at Exts.P10 and P11. The afore steps were challenged by instituting W.P(C) No.35997 of 2018, placing reliance on the tax invoice for the vehicle in question issued by the dealer at Puducherry, registration obtained for the vehicle in question under the Motor Vehicles Act , 1988, from Puducherry and the