Judgment A.K.GANGULY, J. 1. This writ petition has been moved for quashing an order issued under memo No. 15775 dated 22-9-1993 by the Joint Transport Commissioner, Bihar (respondent No, 2). 2. The contention of the writ petitioner is that he purchased .the vehicle in question being No. BHK-5107 on 4/06/1993 and on that very date he took- possession of the vehicle. It has been further stated .in the petition that the additional tax of the bus in question was paid up to 31/12/1992 by the previous owner And the tart token to that effect was issued by respondent No. 3. 3. The petitioner thereafter deposited the tax for the said bus for the period 1-6-1993 to 31-8-1993 and filed an affidavit before respondent No. 3 praying for issuance of tax token for the current period and also for exemption of road tax/ additional tax for the period 1-1-1993 to 31-5-1993 as the petitioner did not ply the said bus as "public service vehicle" for the aforesaid period. 4. According to the petitioner the said bus was registered in the name of the petitioner on 30-7-1993 by respondent No. 3 and the provisional tax token was issued for the period 1-6-1993 to 31-8-1993. The exemption application filed by the petitioner was forwarded by respondent No. 3 to the State Transport Commissioner (Taxing Officer) under Sec. 9A(1) of the Bihar and Orissa Motor Vehicles Taxation Act, 1930 (hereinafter referred to as the said Act) by letter No: 520 dated 19/07/1993 recommending for exemption of payment of tax for the period 1-1-1993 to 31-5-1993. 5. Respondent No. 2 held that the petitioner is liable to pay tax for the said period i.e. 1-1-1993 to 31-5-1993 and passed an order directing realisation of the tax for the said period of 1-1-1993 to 31-5-1993 along with penalty by his order dated 9-9-1993. The said order is the subject matter of challenge in this writ petition. 6. The said order has been challenged, mainly, on the ground that as the petitioner was not the owner or in possession of the vehicle in question between 1-1-1993 and 31-5-1993, he is not liable to pay tax for the said period. In support of his contention, the petitioner relied upon the provisions of Sec. 6 of the said Act, which is set out below:- "6. In support of his contention, the petitioner relied upon the provisions of Sec. 6 of the said Act, which is set out below:- "6. Imposition of tax - (1) As from the first day of January, 1931, and after that date there shall be paid on every motor vehicle a tax at the rate specified in the Second Schedule to this Act.(2) The tax shall be paid annually by the person who keeps a motor vehcile for use Provided that the tax may be paid - (i) for one or more quarterly periods, on payment for each such quarterly period of one-quarter of the annual rate of the tax, (ii), for any period less than a quarterly period expiring on the last date of any quarterly period, on payment of one -twelfth of the annual rate of the tax for every month or part" of a month included in such period, (iii) for one month, commencing from the date of registration at the rate of one-twelfth of the annual rate of the tax where the motor vehicle is temporarily registered under Sec. 25 of the Motor Vehicles Act, 1939 (IV of 1939). (3) The taxing officer shall grant to every person who pays the tax or additional tax in respect of any motor vehicle - (a) a receipt in which shall be specified the particulars of the tax paid and such other particulars as may be prescribed; and (b) a tax token in the prescribed form. 7. The aforesaid Sec. 6 of the Act describes that the tax is imposed on the vehicle in question and the tax has to be obviously paid by the registered owner of the vehicle or by the person who is having possession or control over the vehicle in question. From the scheme of the Act, it is clear that the vehicle in respect of which tax has not been paid remains first charge as would appear from Sec. 11A of the said Act which is set out below:- "11A. Any tax imposed under this Act shall be recoverable as arrear of the tax revenue and shall be a first charge on the motor vehicle in respect of which such tax is payable." 8. Any tax imposed under this Act shall be recoverable as arrear of the tax revenue and shall be a first charge on the motor vehicle in respect of which such tax is payable." 8. From a combined reading of Sec. 6 and Sec. 11A of the Act, it is clear that un-paid tax imposed under the said Act is recoverable as arrear of land revenue and remains the first charge on the motor vehicle in question. As such when the petitioner purchased the vehicle in question on 4/06/1993, he purchased the vehicle with that charge and it is his responsibility to discharge the said liability. The said construction is clear from a plain reading of Sec. 6 read with Sec. 11A of the said Act. The contention of the petitioner that he was not the owner of the vehicle during the intervening period, namely, 1-1-1993 to 31-5-1993 and as such he is not liable to pay the tax is of no consequence what-so-ever, specially in the context of a Taxation law. It is a well known principle of construction of taxation statute that it does not admit of any equitable construction nor is there any room for intendment. .In a celebrated decision of the House of Lords in [St. Aubyn (L.M.) V/s. Attorney General (No. 2)] reported in 1951 (2) All England Law Reports, page 473 Lord Simonds pointed out the principle of consruction of Taxing statute with the usual falicity of expression in these words :- "the question is not at what transaction the section is according to some alleged general purpose aimed, but what transaction its language according to its natural meaning fairly and squarely hits." (emphasis supplied). 9 In this case on plain reading of Sec. 11-A of the Act it is quite clear that the unrealised tax liability on a motor vehicle is its first charge and the petitioner having purchased the vehicle with the said charge cannot deny his liability to discharge the same. 10. The other part of the case, namely, whether the exemption application filed by the petitioner has peen properly considered or not has not been pressed much at the time of hearing of this writ petitioner before this Court. From the impugned order at Annexure 6 it appears that the claim of exemption of tax for the period-1-1-1993 to 31-5-1993 was also properly considered by the relevant authorities. From the impugned order at Annexure 6 it appears that the claim of exemption of tax for the period-1-1-1993 to 31-5-1993 was also properly considered by the relevant authorities. The question whether the vehicle was surendered or was kept parked and the transport authorities were informed about the parking place are all questions of facts and this Court in writ jurisdiction cannot upset a finding arrived at on those questions of fact. The Court has also noted with concern the manner in which the District Transport Officer has granted the provisional tax token without properly adverting to the legal position. 11. No other question is involved in this case. As such this Court is unable to admit this writ petition and the same is hereby dismissed at the admission stage. 12. There will no order as to cost. 13. K. S. PARIPOORNAN, .C. J. :- I agree. Petition dismissed.