With effect from 19 12 1990, the appellant herein, i.e., State of Orissa and its officers, put to change the head of taxation and required the respondent to pay higher tax under Item 4 of the Schedule, whereunder rates of tax are prescribed for motor vehicles plying for hire and used for companyveyance of passengers, including motor cabs.
The Steel Authority of India, the sole respondent herein, employs a fleet of buses meant to carry its employees from its township to its factory at Rourkela.
Challenging such step the respondent Steel Authority of India, moved the High Court of Orissa in a writ petition under Article 226 of the Constitution.
