G. C. BHARUKA, J, J. ( 1 ) THE petitioners are the owners of Goods vehicles, which are registered in the neighbouring states like Kerala and Andhra Pradesh. They ply their vehicles in the State of Karnataka as well on the basis of special permits obtained under Section 88 (8) of the Motor Vehicles Act, 1988 (in short 'the Central Act'), which reads as follows: " (8) Notwithstanding anything contained in Sub-section (1), but subject to any rules that may be made under this Act by the Central Government, the Regional Transport Authority of any one region or, as the case may be, the State Transport Authority, may, for the convenience of the public, grant a special permit in relation to a vehicle covered by a permit issued under Section 72 (including a reserve stage carriage) or under Section 74 or under Sub-section (9) of this section for carrying a passenger or passengers for hire or reward under a contract, express or implied, for the use of the vehicle as a whole without stopping to pick up or set down along the line of route passengers not included in the contract, and in every case where such special permit is granted, the Regional Transport Authority shall assign to the vehicles, for display thereon, a special distinguishing mark in the form and manner specified by the Central Government and such special permit shall be valid in any other region or State without the counter signature of the regional Transport Authority of the other region or of the State Transport Authority of the other state as the case may be. ( 2 ) PRECISELY, the question to be considered in the present cases is as to whether the tourist vehicles registered in other States, which are liable to pay tax under Section 3 (2) read with Item no. 6 of Part-B of the Schedule to the Karnataka Motor Vehicles Taxation Act, 1957, (in short 'the Taxation Act'), are required to pay the same with reference to each special permit at the rate prescribed in Col. 3 of Part-B or they are entitled to pay the tax for 31 days at the rate prescribed under Col. 4 of the said part irrespective of the number of permits they have obtained during that period. 3 of Part-B or they are entitled to pay the tax for 31 days at the rate prescribed under Col. 4 of the said part irrespective of the number of permits they have obtained during that period. ( 3 ) SUB-SECTION (2) of Section 3 of the Taxation Act, reads as under; " (2) Notwithstanding anything contained in Sub-section (1), taxes at the rate specified in Part B of the Schedule shall be levied on motor vehicles suitable for use on roads, which are in the state for periods shorter than a quarter, but not exceeding thirty days. ( 4 ) ITEM-6 of Part-B of the Schedule to the Taxation Act, as it stood at the relevant time, reads as under: PART- b (See Section 3 (2)) item No. Classes of Vehicles For peri at a time 1 2 6. (a) Motor Vehicles other than those mentioned in sub-item (b) 50. 00plying for transport of passengers in respect of which special permit has been issued under Section 88 (8) of the motor Vehicles Act, 1988, and permitted to carry more than twelve passengers (other than the driver and attendant or conductor) for every passenger which the vehicle is permitted to carry. (b) Motor Vehicles (Luxury Buses) plying for hire or reward 100/used for transport of passengers in respect of which special permits have been issued under Section 88 (8) of the Motor vehicles Act, 1988, and complying with Rule 128 of the central Motor Vehicles Rules, 1989, and permitted to carry more than 12 passengers, excluding driver and conductor or attendant, for every passenger which the vehicle is permitted to carry. 7. XX XX ( 5 ) THE question raised herein is a pure question of law based on interpretation of the statutory provisions referred to above. ( 6 ) THE reading of Sub-section (2) of the Section 3 clearly shows that this provision has been engrafted in the Taxation Act for the Vehicles which are registered out of the State of Karnataka and visit the State for short spans of period. The span of period set out in the sub-section is "shorter than a quarter, but not exceeding thirty days. " The expression is not quite intelligible because the period of 30 days will always be shorter than a quarter. The span of period set out in the sub-section is "shorter than a quarter, but not exceeding thirty days. " The expression is not quite intelligible because the period of 30 days will always be shorter than a quarter. I do not propose to resolve this inconsistency in the present proceedings, since it is not very material for the present case. ( 7 ) UNDER Part-B of the Schedule as noticed above rates of taxes have been prescribed for two types for period, namely, (i) for period not exceeding 7 days at a time, and, (ii) for period exceeding 7 days but not exceeding 31 days. ( 8 ) A conjoint reading of Sub-section (2) of Section 3 of Taxation Act with Col. 3 and 4 of Part-B to the Schedule thereof, makes atleast one thing amply clear, namely that the rate of tax which the Legislature intended to prescribe for outside vehicles is for a certain length of period for which the vehicle remains in the State at a time. If it remains in the State for a period up to 7 days at a time, it has to pay taxes at the rate prescribed in Col. 3 of Part-B to the Schedule. But if it remains in the State for a period exceeding 7 days, but not exceeding 30 days then tax in respect thereof has to be paid at the rate prescribed in Co.-4 of Part-B to the Schedule. From the plain reading of the statutory provisions, it is quite clear that the rate of tax or the amount of taxes payable by the outside vehicles has not been correlated either with the number of permits held in respect of those vehicles or with the span of period irrespective of number of visits undertaken by the vehicles during the same to the State. Accordingly, in my considered opinion, whenever an outside vehicle visits the State, each time tax has to be levied on the vehicle, but the rate of tax will depend on the fact as to whether it remains in the State for a period up to 7 days or exceeding the same but up to 30 days. Accordingly, in my considered opinion, whenever an outside vehicle visits the State, each time tax has to be levied on the vehicle, but the rate of tax will depend on the fact as to whether it remains in the State for a period up to 7 days or exceeding the same but up to 30 days. To make it more clear, the liability to pay tax under section 3 (2) will arise on each occasions when the vehicle visits the State, but, the rate of tax payable on such visits will depend upon the length of period for which it has remained in the state. Therefore, the prayer that if the tax is paid at the rate prescribed in Col. 4 of Part-B of the schedule to the Taxation Act, for the period up to 30 days, then the same will hold good for any number of journeys to the State during the said period, cannot be accepted as permissible in law. ( 9 ) THE Writ Petitions are accordingly dismissed, but without costs.