JUDGMENT

PARIPOORNAN, J. :—The appellant, petitioner in Civil Writ Petition No. 144 of 1972, High Court of Delhi, has filed this appeal, on a certificate granted by the High Court under Article 133(1)(a), (b) & (c) of the Constitution of India, against the Judgment of the High Court dated 15-9-1972 (reported in 1973 Tax LR 2546). The appellant company has its registered office at Ghaziabad in the State of Uttar Pradesh. It carries on the business of manufacturing and dealing in Vanaspati and its products. It has a facotry at Ghaziabad. The products are carried on by railway and/or by road into the Union. Territory of Delhi. The Delhi Municipal Corporation Act, 1957 (Act 66 of 1957), hereinafter referred to as the Act, was enacted by Parliament and it came into force on 28-10-1957. Section 178 of the said Act provides for the levy of terminal tax at the rates specified in the Tenth Schedule to the Act on all goods carried by railway or road into the Union Territory of Delhi from any place outside Delhi. Under the said provision, the Delhi terminal tax agency realised a sum of Rs. 2,95,396.01 for the years 1969, 1970 & 1971 as terminal tax from the petitioner on vanaspati products ca