JUDGMENT D. N. CHOWDHURY, J. - The writ petition is directed and arises out of a notice dated December 9, 1993 issued by the Senior Superintendent of Taxes, Tezpur, either to apply for registration or to show cause in writing by appearing in person as to why the petitioner-firm should not be registered under section 12(1) of the Assam General Sales Tax Act, 1993 and why the security money amounting to Rs. 1,00,000 would not be demanded from the petitioner-firm under section 15(1)(a), 15(1)(b) and 15(2) to (4) of the said Act. 2. The petitioner at the relevant time was engaged in the business of sale of cement - a taxable item under the Assam General Sales Tax Act, 1993. The petitioner claimed himself as a dealer in business amongst other in selling cement of a brand known as Vinay Cement manufactured by the Vinay Cement Co. Ltd. The firm registered itself as a dealer under the Assam Finance (Sales Tax) Act, 1956 and submitted its return as an assessee under the said Act up to the period March 31, 1993. After the enactment of the Assam General Sales Tax Act, 1993 which amalgamate, consolidate and amend the laws relating to the levy of tax on the sale or purchase of goods in the State of Assam, the petitioner did not apply for registration under the new Act under section 11(1) of the Act of 1993. According to the petitioner Vinay Cement was exempted from the payment of sales tax on the goods produced by it under the Assam Industries (Sales Tax) Concession Act, 1986 for the period of five years as per the industrial policy of the State of Assam. M/s. Vinay Cement moved the High Court by way of a writ petition challenging the levy of tax during the period of exemption and the High Court by its judgment and order directed the respondents not to demand and realise sales tax from M/s. Vinay Cement. The petitioner in that view of the matter did not apply for registration under the new Act on bona fide belief in spite of the demand from the respondent-authority. The petitioner accordingly submitted a representation before the concerned Superintendent of Taxes. The petitioner in that view of the matter did not apply for registration under the new Act on bona fide belief in spite of the demand from the respondent-authority. The petitioner accordingly submitted a representation before the concerned Superintendent of Taxes. Instead of responding to the representation of the petitioner the respondent issued the impugned notice, the full extract of which is reproduced below : "To M/s. R. K. Supply Corporation Ganesh Mill Compound Nepali Pati - Tezpur. Whereas information is in my possession that you have been selling goods as defined under section 2(15)/operating lease under section 2(25)/executing works contracts under section 2(31) providing hire-purchase facilities under section 2(18) as appended in Schedules II, III, IV, V, VI and VII respectively incorporated under section 8(1)(a), (b), (c), (d), (e) and (f) of the Assam General Sales Tax Act, 1993. And whereas you are liable to get registration under the Act of 1993 w.e.f. July 1, 1993 subject to the provisions contained in section 7(i), (ii) and (iii) of the Act of 1993 but you have not applied for registration as required under section 11(2) of the Act of 1993 as yet in the prescribed manner. Therefore, you are hereby asked either to apply for registration or to show cause in writing by appearing in person before the undersigned on December 17, 1993 at 11 a.m. as to why you will not be registered under section 12(1) of the Act of 1993 by me without further reference and security money for an amount of Rs. 1,00,000 will not be demanded from you under section 15(1)(a) and 15(1)(b) and 15(2) to (4) of the Act of 1993 for effective collection of tax in due course and for proper use and safe custody of declaration, etc." 3. The legality and validity of the impugned notice is assailed in this proceeding by way of the writ petition. 4. According to the petitioner the levy and realisation of sales tax on the sale of cement purchased from industrial unit which was exempted from payment of sales tax under the Act and thus the impugned notice was illegal and without jurisdiction and violative of articles 14, 19(1)(g), 265, 300-A and 301 of the Constitution of India. 5. The respondents did not file any affidavit but submitted the record before this Court. 5. The respondents did not file any affidavit but submitted the record before this Court. From the record it appears that the respondent-authority in exercise of power under section 44(1) of the Act seized the books of accounts and other documents from the petitioner. Thereafter an application was made by the petitioner for resolving the dispute between the parties by an amicable settlement. On November 25, 1993, Mr. Jugal Kishore Tibrewal, partner accompanied by P. C. Bothra, advocate appeared in connection with the verification of the seized books of accounts. The accounts seized were verified and the concerned officer passed the following order : "Mr. Jugal Kishore Tibrewal, partner, accompanied by Mr. P. C. Bothra, advocate appeared in connection with verification of seized B/a. The dealer deals in cement. The accounts seized are verified and found as under : Purchase of Vinay Cement Month Quantity Value July, 1993 2,300 bags Rs. 2,42,500.00 August, 1993 1,810 " Rs. 1,26,000.00 September, 1993 5,820 " Rs. 5,69,100.00 October, 1993 6,580 " Rs. 6,90,900.00 November 1, 1993 to 420 " Rs. 4,10,040.00 November 17, 1993 Sale of Vinay Cement Month Value July, 1993 Rs. 3,21,732.00 August, 1993 Rs. 3,29,706.00 September, 1993 Rs. 5,90,159.00 October, 1993 Rs. 6,70,220.00 November 1, 1993 to Rs. 4,07,421.00 November 17, 1993 The dealer is found to be liable for registration with effect from July 7, 1993 under the provision of section 7 of the Act. Thus, he failed to get himself registered under section 11 of the Act in contravention of section 58 of the Act. Moreover the dealer fails to submit return under section 16 and thus contravenes section 59 of the Act. The dealer submitted that they were of the bona fide belief that Vinay Cement, of which they had the sole dealership is exempted from the purview of tax. The dealer at the same time accepted the offence committed under sections 58 and 59 and pleaded to settle the case in this level, and agreed to pay Rs. 2,000.00 as composition money. After hearing the dealer and considering the nature of offence committed, I agree to compound the case under section 67(1) of the Act." The dealer paid Rs. 2,000 as composition money vide challan No. 22 dated December 6, 1993 and the seized books of accounts were accordingly released by order dated December 6, 1993. 2,000.00 as composition money. After hearing the dealer and considering the nature of offence committed, I agree to compound the case under section 67(1) of the Act." The dealer paid Rs. 2,000 as composition money vide challan No. 22 dated December 6, 1993 and the seized books of accounts were accordingly released by order dated December 6, 1993. The petitioner-firm was registered as a dealer under section 11(3) of the Act fixing liability with effect from July 1, 1993 and after hearing the dealer found it reasonable to impose the security of Rs. 1,00,000 under section 15(1)(a) for the timely deposit of the taxes. Accordingly the registration certificate and demand of security were issued. 6. Mr. H. N. Sarma, learned Additional Senior Government Advocate appearing on behalf of the respondents accordingly submitted that the writ petition has become infructuous and the same is liable to be dismissed as infructuous. 7. I have given my anxious consideration on the matter. Section 7(1) of the Act imposes liability upon the dealer to pay tax under the law. The tax leviable under section 7 for any year shall be charged on the taxable turnover during such year as per section 8 of the Act. The Legislature accordingly prescribed the rate of tax within its legislative competence. An express grant of statutory powers carries with it by necessary implication, the authority to use all reasonable means to make such grant of power efficacious. The hostile plea of discrimination between the manufacturer and the dealer bears no merit. There cannot be equality amongst the unequals. Article 14 only prohibits class legislation but does not forbid reasonable classification. The right to equality does not take away from the State power of classifying persons for legitimate purposes. All differential treatment cannot be labelled as violative of the equality clause enshrined in article 14 of the Constitution of India. Article 14 does not demand the legislative classification should be in mathematical precision and logically faultless. 8. Upon considering all aspects of the matter, I do not find any merit in the writ petition and accordingly the same is dismissed. However, there shall be nor order as to costs. Writ petition dismissed.