D. D. SINHA, J. :-Heard the learned senior counsel for the petitioner and the learned AGP for the respondents. The petitioner is challenging 173 demand notices (hereinafter referred to as the "impugned demand notices"), calling upon the petitioner to pay to respondent No.1 alleged outstanding tax on motor vehicles of the petitioner and alleged interest accrued thereon amounting to Rs.97,48,461/-.

2. The petitioner is a Company registered under the Indian Companies Act, 1913 having its registered office at 24 Homi Mody Street, Fort, Mumbai 400 001 and its manufacturing plants, among other places at Pimpri, Chinchwad and Chikhali. Respondent No.1 is the Deputy Regional Transport Officer of Pimpri-Chinchwad, a Taxation Authority appointed under the Motor Vehicles Act, 1988 within whose jurisdiction the plants and factory premises of the petitioner are situated. Respondent No.2 is the Tahsildar of Pune, city Pune, appointed under the provisions of Maharashtra Land Revenue Code 1966. Respondent No.3 is the Police Inspector of the Pimpri Police Station at Pimpri, Pune. Respondent No.4 is the Appellate Authority, under Rule 28 of the Bombay Motor Vehicles Tax Rules 1959 (hereinafter referred to as the 'Tax Rules') against all the orders passed by any Taxation Authority i.e. respondent No. 1. Respondent No.5 is the Deputy Transport Officer, Pune and respondent No. 6 is the Assistant Regional Transport Officer, Pune.

3. The brief facts, which have given rise to filing of the petition, are as under-

(a) The petitioner is engaged in the business of manufacturing and sale of commercial vehicles and passenger cars at its manufacturing plants at Pimpri, Chinchwad and Chikhli, Pune.

(b) The petitioner also owns a number of motor vehicles of various kinds• such as buses, trucks, jeeps, cars, forklifts etc. in connection with its business. On the date of filing the appeal before respondent No.4, the petitioner had 1417 (one thousand four hundred seventeen) motor vehicles which are registered with the Registering Authority i.e. Regional Transport Office, Pune, under the Motor Vehicles Act, 1988.

(c) Out of the total 1417 motor vehicles, the petitioner had been using some motor vehicles exclusively within its factory premises at Pimpri, Chinchwad and Chikhali, Pune (hereinafter referred to as the 'factory premises') for the purpose of internal transportation of materials and equipments within its own factory premises and for other purposes necessary and incidental to the manufacturing process. The said motor vehicles are used only within the factory premises. None of these vehicles are taken out of the Factory Premises for other use. The said motor vehicles are never used or kept for use on any of the roads maintained by the State of Maharashtra or local authority or any governmental agency (hereinafter referred to as the 'said Motor Vehicles' ).

(d) It is further contended that no member of public is given any right of access to the said Factory Premises. The Factory Premises of the petitioner at Pimpri, Chinchwad and Chikhli are spread over an area of about 376.126 and 188 acres respectively. The said Factory Premises are enclosed by compound wall constructed by the petitioner and the ingress and egress is regulated through the gates provided at the respective factories. Only those persons who are authorized to enter are given gate pass by the Security Department of the petitioner. The Security Department can refuse entry at the main entrance in the absence of proper authority. In addition to the Industrial sheds and other structures in the said premises, there are open spaces and roads which are constructed and maintained by the petitioner alone. The said roads within the Factory Premises are neither constructed by nor maintained by the State I Local Authority. The movement of vehicles within the factory premises is also controlled and regulated by the petitioner alone.

(e) The petitioner had been duly declaring the 'non-use' of the said Mo