N.G. Das, J.- This is an appeal against the judgment and order of learned Single Judge dated 21.7.1995 whereby the learned Single Judge dismissed the Civil Rule No.569 of 1994 with the findings that the rules which the petitioner challenged in the writ petition are neither unconstitutional nor ultra vires. Those are regulatory in measure an(l as such those rules are not oppressive and unreasonable. 2. We have heard Dr. AK Saraf, the learned counsel appearing on behalf of the appellants and Mr. A. Chakraborty, the learned Advocate General appearing on behalf of the respondents. 3. The facts of the case, in brief, are that the appellants who challenged the constitutional validity of the Tripura Sales Tax (11th Amendment) Rules, 1994 (hereinafter referred to as the Rules), provisions of sections 29, 32 and 36A of the Tripura Sales Tax Act (hereinafter referred to as the Act) and the notification dated 23.9.94 and 15.10.94 claimed to be transporters doing business of transporting goods after obtaining necessary registration. It is stated that the appellants being transporters they are acting as carriers within the meaning of section 2 of the Carriers Act, 1865 and on instructions from their clients they carry goods by road either within Tripura or to a place outside Tripura and for such services they are remunerated by their clients. The appellants are, therefore, nothing but transporters and they are not dealers manufacturing or importing taxable goods in Tripura. 4. But by virtue of the Rules, 1994 effective in the State of Tripura from 13th day of September, 1994 whereby sub-rule (3) has been inserted under sub-rule (2) of Rule 46A of the Tripura Sales Tax Rules, 1976 and insertion of sub-rule (1) (a) after sub-rule (1) and substitution of sub-rule (2) in Rule 63 A in the old sub-rule (2) in the principal Rules and Rule 64A, the appellants have been debarred from carrying on their business unless they are registered as transporters with the Commisioner of Taxes in such manner as he may direct. It is stated that by virtue of insertion of sub-rule (3) after sub-rule (2) of Rule 46A of the Rules, the transporters are required to obtain Form XXIV from the Superintendent of Taxes concerned on payment of such price as may be specified by the Commissioner and such Form shall be serially numbered and account has to be maintained in the register. 5. 5. It has been contended in the writ petition that the appellants who are transporters are merely carriers, trustees or bailees of the goods belonging to others for the time being and they are not engaged in selling goods at any point of time. Therefore, they are not dealers and hence the provisions for payment of penalty on composition of the offences is arbitrary. It has been further contended that furnishing of particulars under Form No.XXIV is nothing but an additional burden on the transporters and this is also contrary to the Carriers Act, 1865. The obligation cast upon the transporters by amendment particularly in Rules 46A (3), 63A (1) (a) and 64A are alleged to have been sought to equate transporters with dealers and hence this provisions are oppressive. 6. It is further contended that appellants being transporters the respondents are not entitled to make any provisions under Entry No.54 of List 2 of the Seventh Schedule of the Constitution of India. It is stated that obligation put on the appellants Association to maintain accounts, to get themselves registered, to produce the books of accounts as and when demanded and also to procure form and imposition of penalty by way of composition of offences are in exercises of the powers conferred by Entry No.54, List 2 of the Seventh Schedule of the Constitution of India and therefore, the said provisions of law are ultra vires and illegal. It has, therefore, been further stated that those provisions are totally violative of the constitutional provisions like Articles 14, 19 (1) (g), 246 and 265 of the Constitution of India. 7. It is stated that since the appellants are not the dealers they are neither liable for payment of sales tax nor are responsible for its evasion inasmuch as they are not dealers within the meaning of the Act. It has also been alleged that the appellants are being harassed on flimsy grounds by the Checkpost authorities functioning under the respondent No. 1 without affording any opportunity to its members to explain the alleged difficulties or discrepancies, if any. 8. It has been further contended that the appellants can at best give particulars of the goods carried by them or of the consignors or consignee to whom the goods belonged. But it is not possible for them to question about the correctness of such particulars from those persons booking the goods. 8. It has been further contended that the appellants can at best give particulars of the goods carried by them or of the consignors or consignee to whom the goods belonged. But it is not possible for them to question about the correctness of such particulars from those persons booking the goods. It is stated that goods are carried by hand-cart wallas or drivers who have no idea about the goods to be consigned. Therefore, the transporters cannot be asked to give particulars other than which they record in their books. The imposition of the obligation requiring the transporters to pay tax under the impugned provisions by way of obtaining registration is violative of Article 14 of the Constitution of India. Hence, such a provision is ultra vires as section 38 of the Haryana General Sales Tax Act, 1973 imposing a duty on a person transporting goods was held to be beyond the purview of State Legislation by the Supreme Court. 9. The appellants have, therefore, prayed for issuance of a writ of Madam us quashing the provisions of section 36A of the Act, Rules 46A (3), 63 A (1) (a), 63 A (2), new Rule 64A as introduced in the Tripura Sales Tax Rules, 1976 and also the notification bearing No.F.1-1 (27)/Tax/94/7215-88 dated, 23rd September, 1994, Memo No.F.l-(27-Tax-94/7305-77, dated 23rd September, 1994 and Memo No.F.1-1 (27)-Tax/94/7365-935, dated 15th October, 1994 (Annexure 1). The appellants also prayed for a further declaration mat the provision of section 29 and section 32 of the Tripura Sales Tax Act, 1976 were not applicable in the case of transporters. 10. The responents resisted the writ petition by filing a joint affidavit-in-opposition wherein they have stated, inter alia, mat this writ petition was nothing but a speculative attempt to evade their responsibility in importing and exporting various goods in Tripura and outside Tripura. The petitioners are not entitled to claim exemption from being checked by the respondents at any point of time or at any place inside Tripura while carrying taxable goods without giving necessary declaration in the relevant documents. The transporters cannot evade their responsibility to check up the goods to be transported outside Tripura. The transporters are, therefore, duty bound to furnish their particulars to the respondents so that the latter can trace out the whereabouts of the transporters. The transporters cannot evade their responsibility to check up the goods to be transported outside Tripura. The transporters are, therefore, duty bound to furnish their particulars to the respondents so that the latter can trace out the whereabouts of the transporters. In absence thereof it is absolutely impossible to bring the offended transporters in book while they are transporting the goods violating the law and order of the State to evade tax. Since, the transporters are carrying the taxable goods they are bound to furnish the names and particulars of the dealers. 11. It is contended that the statement that transporters are forced to pay penalty is absolutely a wrong statement as the provisions made in this regard left a discretion with the transporters to elect whether they desire to be prosecuted or to pay penalty in lieu of prosecution when they are found to have violated the provisions of the Tripura Sales Tax Act and Rules. It is the duty of the transporters to see whether they are carrying taxable goods or not. 12. It has been further contended that the transporters carrying goods without any declaration and sometime they carry goods with declaration as 'self and by way of carrying goods in this way they tried to evade payment of tax. 13. In the background of these facts it is contended that the Rules 46A, 63 A and 64A of the Rules, 1994 are regulatory provisions to check evasion of tax. By making the provisions for registration of the transporters, carriers or transporting agency no obligation as dealer has been cast upon them. The State Legislature is, therefore, quite competent to enact such provision in the interest of the State revenue. It is further stated that section 29, 32 and 36A of the Act were provided in the Act long back and those provisions' were never challenged before this writ petition. The provisions so made are regulatory in character and as such they are not violative of any provisions of the Constitution of India. It has also been contended that petitioners do not discharge their duty as a common carrier as prescribed for in the Carriers Act, 1865. Rather they are transporting undeclared/misdeclared and self declared taxable goods violating the relevant provisions of the Act and Rules,. It has also been contended that petitioners do not discharge their duty as a common carrier as prescribed for in the Carriers Act, 1865. Rather they are transporting undeclared/misdeclared and self declared taxable goods violating the relevant provisions of the Act and Rules,. In case any transporter is found to have violated the provisions of the Act and Rules at the time of transportation of the goods penal actions are taken against the transporters. But they are not treated as dealers and no punishment was also awarded to them as dealers. What sub-section (2) of section 38 of the Tripura Sales Tax Act, 1976 envisages is that every person transporting taxable goods is to file a correct and complete declaration of the goods being transported. Only those goods which are found to have been declared or to have been declared incorrectly these are only seized. 14. It is stated that Tripura Sales Tax (11th Amendment) Rules, 1994 has been made with a view to checking the malpractices of the transporters. The introduction of Form XXIV to be filled up by the transporters is for the purpose of having full knowledge about which transporters had utilised how many such forms and in what manner. It is denied that transporters have been equated with the dealers by the aforesaid Amendment Rules, 1994. The import of any taxable goods in the State by any unregistered dealer has been banned by the Government. So, if goods are delivered to the dealers without due permits then there is scope for evasion of sales tax. The purpose of section 36A and filling up of Form XXIV are for the purpose of checking of evasion of tax - the provisions of sections 46A, 63A (1) (a) and Rule 46A are regulatory measures to ensure payment of tax to the Government. The object of registration of the transporters is to get the particulars of the transporters as most of the transporters who are doing business in Tripura are outsiders and the tax collecting authority do not have the full details i.e. names, address of all the partners, location of office and godown, particulars of persons duly authorised to represent the transport company etc. These particulars are necessary when a particular transporter is needed to be prosecuted in a Court. The introduction of Form XXIV which is obtainable on payment of a fee of Re. These particulars are necessary when a particular transporter is needed to be prosecuted in a Court. The introduction of Form XXIV which is obtainable on payment of a fee of Re. 1/- is for the purpose of stopping transportation of unauthorised and undeclared goods evading tax. 15. As regard the contention that the Stated-Legislature is not competent enough to frame such Rules under Entry No. 54 of List 2 of the Seventh Schedule, it is stated that under the aforesaid entry powers have been conferred upon the State Legislature to enact laws relating to taxes on sale of goods. 16. So for as section 29 is concerned, it is stated that this provision comes into play only in respect of the transporters who do not maintain any books of account with the sole object of evading tax. It is, however, admitted that transporters are not buyers or sellers of taxable goods, but when they carry undeclared, misdeclared and self declared goods, they becomes casual traders in disguise. Hence, to check such unscrupulous transporters the aforesaid measures under the amended provisions of the Rules have been made. 17. As regard the allegation that the transporters are being harassed at the check post it is stated that whenever any transporters reports any case of harassment or illegal seizure such case is immediately looked into and when such allegation is found to be true the Superintendent of Taxes at Churabari release the goods immediately. It is not true that they are detained on flimsy grounds. 18. It was further stated that on 4.12.94 the Commissioner of Taxes was present at Churabari Checkpost when M/s Paul Road Link, a member of the petitioners Association gave a declaration in Form No.XXIV mat vehicle TRL 3516 carried only non taxable goods viz sugar and chira. But when the vehicle was searched by the Tax Official at Churabari it was found that there were 48 tins of vanaspati, 8 package of candle and 10 big drums of rubber solution which are all taxable goods (R/5 series). 19. It was further stated that transporters while violating the provisions of the Act and Rules are required to pay composition money in lieu of prosecution under section 32 of the Act. It has, therefore, been denied that the Rules of 11th Amendment are directly conflicting the Act of 1976. 20. 19. It was further stated that transporters while violating the provisions of the Act and Rules are required to pay composition money in lieu of prosecution under section 32 of the Act. It has, therefore, been denied that the Rules of 11th Amendment are directly conflicting the Act of 1976. 20. Only taxable goods are seized at the Checkpost for want of proper declaration. 21. It is stated that after crossing the Check Post the goods are taken direct to the godown of the transporters and no accounts are being maintained. Apart from that some transporters delivered those taxable goods to dealers registered or unregistered without permits from the Superintendent of Taxes. Consequently, it becomes very easy to evade sales tax because no record is maintained (R/7). It has, therefore, been averred that the Rules so framed requiring the transporters to furnish particulars are only for the purpose of safeguarding and ensuring proper collection of taxes in the interest of public exchequer. 22. Learned Single Judge after evaluation of the facts in the context of the decisions referred to by the learned counsel for the appellants arrived at the conclusion that the Rules so challenged are regulatory in measure for the purpose of preventing evasion of taxes. It was held by the learned Single Judge that the Rules were suited to articulate the needs of the community and those were within the bounds of the legislative competence. With these findings the learned Single Judge dismissed the writ petition and hence this appeal. 23. The question which have, therefore, arises for decision in this appeal are whether the purposes of sections and rules mentioned above are tenable in law and whether State Legislature has the competence to make these provisions for the purpose of preventing evasion of taxes. 24. Dr. Saraf, the learned counsel appearing on behalf of the appellants has at the very outset submitted that the provisions of the Act and Rules which the appellants challenged are beyond the powers of the authority as they are not regulatory in nature, but prohibitory and restrictive. Dr. 24. Dr. Saraf, the learned counsel appearing on behalf of the appellants has at the very outset submitted that the provisions of the Act and Rules which the appellants challenged are beyond the powers of the authority as they are not regulatory in nature, but prohibitory and restrictive. Dr. Saraf has at first challenged the competence of the State Legislature to make any law as is done under section 3 6 A of the Tripura Sales Tax Act, 1 976 (for short the Act) requiring the transporters or transporting agents for maintaining proper accounts of goods transported to or outside Tripura as according to him imposition of such obligation on the transporters are not within the ambit of Entry 54 of List 2 of the Seventh Schedule. In this context Dr. Saraf has also assailed the provisions made under Rule 64A of the old Rules. The first question which, therefore, arises for consideration is whether the State Legislature has the legislative competence to make any law as is done under section 36A of the Act and Rules 64 A of the old Rules. 25. It may, therefore, be advantageous to extract section 36A of the Act and Rules 64A of the old Rules. Section 36A of the Act reads as follows : "36A. Maintenance of Accounts by Carriers : (1) Notwithstanding anything contained in any other Act, any transporter, carrier or transporting agent operating its transport business in Tripura, shall maintain proper account of goods transported to or outside Tripura through it in the manner prescribed and shall on demand by the Commissioner be liable to furnish in the prescribed manner such information as the Commissioner may require relating to the transportation of such goods and shall also be bound to produce books of accounts for inspection and examination by the Commissioner." Rule 64A of the old Rules reads as : "64 A. (1) Every transporter, carrier or transporting agent operating its transport business in Tripura shall maintain in a Register in Form No.XXII, a true and correct account of every consignment of goods transported into Tripura, and in Form No.XXIII of goods transported outside, through it. (2) No taxable goods shall be delivered by the transporters, carriers or transporting agents, unless the requirements laid down in Rule 46 and 47 have been complied with." 26. (2) No taxable goods shall be delivered by the transporters, carriers or transporting agents, unless the requirements laid down in Rule 46 and 47 have been complied with." 26. It would be apparent from the above quoted provisions that by section 36A of the Act the State legislature required the transporters, carriers to maintain proper accounts of goods which they will transport to Tripura or outside Tripura in the manner prescribed by the Commissioner and the Commissioner may also send for the books of account for inspection. Rule 64A of the old Rule requires the transporters, carriers or transporting agents to maintain register in Form No.XXII and also a true and correct accounts of every consignment of goods transported into Tripura in Form No. XXIII. Sub-rule (2) of Rule 64A relates to the dealers only. 27. It is. submitted by, DC. Saraf that the above quoted provision are nothing but short of restriction on the transporters to carry on the transport business, and the provision requiring them to furnish the particulars, information etc regarding consignments handled by them is beyond the purview of State Legislature. In support of his contention Dr. Saraf has placed reliance upon a decision of the Supreme Court rendered in the case of State of Haryana & others vs. Santlal & another, reported in 91 STC 321. 28. In that case section 38 of the Harayana General Sales Tax, 1973 was challenged. By section 38 of the Haryana General Sales Tax Act, 1973 a duty was imposed on clearing or forwarding agents or dalal or other persons transporting the goods to furnish particulars and information regarding consignments handled by them and requiring them to take out a licence before carrying on business. It was held that this provision was beyond the purview of the State Legislature and consequently all the Rules and forms in the Haryana General Sales Tax Act, 1975 were declared ultra vires and bad in law. 29. Mr. A. Chakraborty, the learned Advocate General on the other hand has contended that this decision is not applicable to the present case as a perusal of the provisions of section 36A of the Act and Rule 64A of the old Rules will make it clear that these provisions are nothing but regulatory measures for the sole purpose of preventing evasion of tax. According to him the obligation for furnishing information by the aforesaid provisions do not in any manner impede or hamper the free flow of trade and as such those provisions do not contravene the provisions of Article 301 of the Constitution of India. 30. Now on perusal of the judgment of the learned Single Judge we find that learned Single Judge under paras 35 and 42 of his judgment dealt with the provisions laid down under section 38 of the Haryana General Sales Tax Act vis-a-via the provisions of Rule 46A (3), Rule 63A (1) (a), Rule 63A (2), Rule 64A and the provisions of section 29, 32 of the Act. As already stated section 36A requires maintenance of proper accounts of goods transported to Tripura or outside Tripura. Rule 64A prescribed the Forms in which a register has to be maintained and the accounts of every consignment of goods transported into Tripura. 31. Sub-section (1) of section 3 8 of the Haryana General Sales Tax Act on the other hand requires every clearing or forwarding agents, dalal or other persons transporting goods within the State, who, during the course of his business handles documents of title to goods for or on behalf of any dealer to furnish to the assessing authority such particulars and information as may be prescribed. It was observed that the "documents of title to goods" was not made clear in the said Act. Section 36A as quoted above does not require the transporters or transport agency to furnish such information. What is required by section 36A of the Act is for maintaining proper accounts of goods transported to or outside Tripura and if necessary and called by the Commissioner those are to be produced before him. The Form No.XXII in which a register is to be maintained is as follows: "FORM XXII The Tripura Sales Tax Rules, 1976 Register of Goods Transported into Tripura (See Rule 64A) Date and Lorry Manifest No.Permit No. CN Nos Descri- Time of No. and date with date of with ption of arrival of Churaibari date goods Lorry. Check Post 1 2 3 4 5 6 Quantity Name of the Name of the Permit No. Signature with date of or declared, consignor, consignee. and date of the person and the the ST again- name of the dealer on st which deli- which behalf the deliv- very made, ery is taken. Check Post 1 2 3 4 5 6 Quantity Name of the Name of the Permit No. Signature with date of or declared, consignor, consignee. and date of the person and the the ST again- name of the dealer on st which deli- which behalf the deliv- very made, ery is taken. 7 8 9 10 11 32. It would appear from the above quoted form in which a register has to be maintained by the transporters/transport agency that the particulars and informations which are to be recorded must be within the knowledge of the transporters/transport agency. As for at the time of booking the consignment of goods the transporters/transport agency must be knowing the weight of the consignment as they will have to charge the transportation cost on the basis of weight of the load. They must also be knowing the name of the consignee. To know the description of the goods to be carried must be within the knowledge of the transporters as without knowing the description of the goods the transporters/transport agency cannot carry the goods. Similarly, the other informations, namely, permit number, CN Number etc can be obtained at the time of booking. It is, however, contended in the writ petition that generally illiterate persons like labourers or handcartwallas or drivers etc come to a transporters' office for entrusting the goods for carriage or for taking delivery of the goods on behalf of the consignee. That may be a fact, but this does not necessarily mean that under this pretext a transport agency can avoid furnishing the information and particulars to the assessing authority of a border State like Tripura as it has been contended that on some occasion it was found that transporters are carrying taxable goods through Check Post without documents and on behalf of some unscrupulous transport agency forme sole purpose to cause evasion of tax and by such act they have been acting as agents of the dealers who clandestinely doing business of taxable goods evading tax. In the counter affidavit it was specifically stated that M/s United Trade and Transport did not maintain such records for a long time and in another case M/s North Eastern Carrying Corporation delivered taxable goods without permit. 33. In the counter affidavit it was specifically stated that M/s United Trade and Transport did not maintain such records for a long time and in another case M/s North Eastern Carrying Corporation delivered taxable goods without permit. 33. Now, if the provisions of section 36 A and Rule 64 A are compared with that of section 38 of the Haryana General Sales Tax Act and the Rules made 8 thereunder it would be apparent that while Rule 48 of the Haryana General Sales Tax Rules speaks of the licence that the clearing or forwarding agents or dalal or persons for transporting goods has to obtain; no such clause is there under section 36A or Rule 64 A of the said Act and Rules of Tripura. Moreover, there is no provisions requiring the transporters/transport agency to furnish particulars or information of the documents of title to goods. In the case of State of Haryana (supra) it was observed that the expression "documents of title to goods" did not define what it precisely meant. The facts of the case of State of Haryana (supra) being quite distinguishable from the present one, the decision of that case is not applicable to the present one. 34. The next decision referred to by Dr. Saraf is a decision rendered in the case of Bharat Singh vs. State of Haryana & others reported in 1996 STC (1995) 227. This case came before the Punjab and Haryana High Court challenging the legality and validity of the sections 37 and 38 of the Haryana General Sales Tax Act. Under the principal Act a contractor of Railway booking agency was not required to obtain any licence under the provisions of Haryana General Sales Tax Act, 1973 nor he requires to submit any return of the transaction of goods. Later on the Act was amended in 1983 and under the amended provision the contractor was required to obtain a licence on payment of prescribed fees and he was further required to give particulars and informations in respect of transaction of goods as provided under the amended Act. Failing which he is liable to pay equivalent to 20% of the value of the goods in respect of which particulars and informations have not been supplied. Both the sections 37 and 38 were declared invalid. Such a provision is actually not there in the rules under attack. 35. Mr. Failing which he is liable to pay equivalent to 20% of the value of the goods in respect of which particulars and informations have not been supplied. Both the sections 37 and 38 were declared invalid. Such a provision is actually not there in the rules under attack. 35. Mr. A. Chakraborty, the learned Advocate General has argued that the Rules under attack were found to be necessary in the public interest to prevent evasion of taxes and to enforce payment of tax as cases of evasion of taxes become rampant in the State of Tripura. It is submitted by learned Advocate General that law regarding interpretation of legislative entity must be considered in their widest amplitude and in deciding such a question a just plea has to be judged between the restrictions imposed and the interest of the general public. 36. Dr. Saraf lias, however, contended that so far as interpretation of statutes is concerned one has to look merely what is normally said and there is no room for intendment. In support of his contention Dr. Saraf has placed reliance upon a decision of the Supreme Court rendered in the case of Smti Tarulata Shyam & others vs. Commissioner of Income Tax, West Bengal, reported in (1977) 3 SCC 305 . This case relates to some provisions of the Income Tax Act, 1922 which were inserted in the Act by Finance Act, 1955 by adopting corresponding section 108 of the Common Wealth Income Tax Assessment Act. Under para 35 of the judgment their Lordships made the following observation : "To us, there appears no justification to depart from the normal rule of construction according to which the intention of the legislature is primarily to be gathered from the words used in the statute. It will be well to recall the words of Rowaltt, J., in Cape Brandy Syndicate vs. IRC at p.71, that "in a faxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to a tax. Nothing is to be read in, nothing is to be implied. There is no room for any intendment. There is no equity about a tax. There is no presumption as to a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used." Once it is shown that the case of the assessee comes within the letter of the law, he must be taxed, however great the hardship may appear to the judicial mind to be." 37. In this context, the Supreme Court in the case of State of Bihar vs. Harihar Prasad Debuka reported in (1989) 73 STC 353 (SC) : AIR 1989 SC 1119 reversing the Full Bench decision of the Patna High Court in Harihar Prasad Debuka vs. State of Bihar (1987) 66 STC 178 : AIR 1987 Patna 175 (FB) their Lordships of the Supreme Court held : "While examining whether there is a violation of the freedom guaranteed by Article 301, one has to scrutinise whether the impugned legislative or executive act operates to restrict or barricade trade, commerce or intercourse directly and immediately, as distinct from creating some indirect or inconsequential impediment which may be regarded as remote. In otherwords, regulatory or compensatory measure cannot be regarded as violative of the freedom. Such measures may be of diverse nature or various kinds such as traffic regulation, making of declarations and filing of returns within reasonable limits. Such measures cannot be challenged as interfering with the freedom guaranteed by Article 301 unless they are known to be colourable measures to restrict the free-flow of trade, commerce and intercourse." 38. Keeping the above decisions in view if we look back to the provisions as discussed above it will appear that the particulars and informations which are required to be furnished under the provisions of section 36A and Rule 64A are regulatory measures only to check evasion of tax and the interruption caused to the moving vehicle for the purpose of checking whether tax is being evaded or not does not amount to impeding the free-flow of trade attracting Article 301 of the Constitution. 39. For all these reasons, we hold that the provisions laid down under section 36A and Rule 64A do not offend Article 301 or Articles 14 and 19 (1) (g) of the Constitution and as such those provisions are not beyond ancillary and subsidiary of powers of the legislature. 40. 39. For all these reasons, we hold that the provisions laid down under section 36A and Rule 64A do not offend Article 301 or Articles 14 and 19 (1) (g) of the Constitution and as such those provisions are not beyond ancillary and subsidiary of powers of the legislature. 40. The next contention urged by Dr. Saraf is that the provisions of section 32 requiring the transporters for making the payment of composition money is not permissible under the law. The State in its counter stated that proceedings for composition of offence at the Check Post are completed on the basis of the offers made by the defaulting transporters, dealers and on accepting the said offers by the taxing authority. In such proceeding the defaulting transprters/dealers are given sufficient opportunities of being heard and on maintaining the principle of natural justice those proceedings are completed. A perusal of the provision of section 32 of the Act makes it abundantly clear that the defaulting dealer or agents may contest the case which has been registered against him and avoid payment of composition money. On the other hand, if he agrees to pay the composition money then the proceedings which were started against him would be dropped. It is, therefore, found that it is an option given to the defaulting dealers/agents. There is no compulsion in this provision that he should be bound to pay the composition money. 41. Learned Advocate General has contended that it cannot be denied that this tiny State of Tripura is virtually surrounded by Bangladesh and this aspect cannot be ignored. It is true that this State is a border State bounded on the majore three sides by Bangladesh. The particulars and informations required to be furnished in prescribed form after registration do not, in our view, put any restriction of the inter State trade. A mere stoppage of the movement of the vehicle for checking will not harm any direct or immediate effect on the trade. I We cannot ignore the geographical situation of the State. Should a transport I agency be allowed to carry taxable goods for which no permit was obtained ? 42. A mere stoppage of the movement of the vehicle for checking will not harm any direct or immediate effect on the trade. I We cannot ignore the geographical situation of the State. Should a transport I agency be allowed to carry taxable goods for which no permit was obtained ? 42. We are, therefore, of opinion that provisions of the sections and rules which have been challenged are regulatory measures merely to check evasion of tax and interruption caused to the carrying vehicles for the purpose of checking whether tax is being evaded or not, does not amount to impeding of free-flow of trade. In our considered view the provisions of-law contemplated under section 29 and 32 of the Tripura Sales Tax Act, 1976 are applicable in case of transporters. The State Legislature is competent enough to frame/make such rules mentioned above under Entry No.54 of List 2 of the Seventh Schedule of the Constitution of India. 43. For the reasons stated above, the appeal is dismissed. Interim order stands vacated. There will, however, be no order as to costs.