ORDER K. RAVIRAJA PANDIAN, J. - The petitioner has filed the writ petition seeking for issuance of a writ of certiorari calling for the records pertaining to the order passed by the first respondent in RP No. JJ2/RP/MV/88/2001 dated April 1, 2002 and quash the same. The writ petition is filed against the order of the Joint Commissioner in revision proceedings dated April 1, 2002. The assessee is a dealer in two wheelers and he paid the tax under the Tamil Nadu General Sales Tax Act, 1959 for the sale of its vehicles, without paying entry tax under the provisions of the Tamil Nadu Tax on Entry of Motor Vehicles into Local Areas Act, 1990 for use or sale. Thereafter, the Deputy Commercial Tax Officer, Thanjavur levied tax for the vehicles brought into the local area and gave set-off of the Tamil Nadu general sales tax amount paid in respect of the sale of the vehicles by the dealer. Thus, there is a balance amount of one per cent of the sale value. For the same, penalty under section 15(1) for a sum of Rs. 5,89,590 and penalty under section 15(2) for a sum of Rs. 5,35,068 has been imposed by the Deputy Commercial Tax Officer by order dated November 19, 2001. Aggrieved by that order, the petitioner preferred the appeal before the Appellate Assistant Commissioner (CT), Thanjavur who confirmed the order of the Deputy Commercial Tax Officer. The assessee put in the order of the Appellate Assistant Commissioner, Thanjavur in revision before the Joint Commissioner. The Joint Commissioner while confirming the levy of entry tax and the penalty under section 15(2), has reduced the penalty under section 15(1) to Rs. 10,000 from Rs. 5,89,590. The correctness of the said order is now assailed before this court. The learned counsel for the petitioner very strenuously contended that as he has paid the tax under wrong head, such payment of tax under the wrong head, cannot be considered as illegality to levy penalty under different statute. For that purpose, the learned counsel relied on the decision reported in [2003] 131 STC 73 (Mad) (Kasi and Sethu v. Deputy Commercial Tax Officer (DG-CTO), Kumbakonam). The facts in this case are very clear. The petitioner has to pay the entry tax as and when the vehicles have entered into the local area, i.e., Thanjavur, but he did not pay any entry tax. The facts in this case are very clear. The petitioner has to pay the entry tax as and when the vehicles have entered into the local area, i.e., Thanjavur, but he did not pay any entry tax. However, it is seen from the order, the petitioner has paid the Tamil Nadu general sales tax as and when the vehicles are sold. As per the statutory provision, in particular, section 3 of the Tamil Nadu Tax on Entry of Motor Vehicles into Local Areas Act, 1990 which provides for levy of tax, reads that subject to the provisions of this Act, there shall be levied and collected a tax on the entry of any motor vehicles into any local area for use or sale therein which is liable for registration, or for the assignment of a new registration mark, in the State under the Motor Vehicles Act, 1988 (Central Act No. 59 of 1988). Sub-section (1) of section 4 provides for reduction in tax liability which reads where an importer of a motor vehicle liable to pay tax under this Act, being a dealer in motor vehicles, becomes liable to pay tax under the General Sales Tax Act and additional sales tax under the Tamil Nadu Additional Sales Tax Act, 1970 (Tamil Nadu Act No. XIV of 1970) by virtue of the sale of such motor vehicle, then his liability under those Acts shall be reduced to the extent of tax paid under this Act. Sub-section (2) is not relevant to this case as the petitioner is a dealer. As per section 3 as and when the vehicle is brought into the notified area, the petitioner has to pay the entry tax. By virtue of section 4 of the Entry Tax Act, as and when sales tax is payable, the amount of sales tax will be get adjusted or given set-off under the sales tax proceedings. In other words, as and when the assessment is made under the sales tax, the tax due under the assessment will be adjusted in the amount of tax made in the Entry Tax Act. But, insofar as the present case is concerned, the petitioner has paid the sales tax and not the entry tax for the year 1994-95. In other words, as and when the assessment is made under the sales tax, the tax due under the assessment will be adjusted in the amount of tax made in the Entry Tax Act. But, insofar as the present case is concerned, the petitioner has paid the sales tax and not the entry tax for the year 1994-95. Subsequently, entry tax assessment has been made and the difference of one per cent between the Tamil Nadu general sales tax already paid and the entry tax assessment made has been collected from the petitioner. For the belated payment of entry tax, section 15(1) of the Entry Tax Act provides that; "where any person liable to pay tax under this Act fails to comply with any of the provisions of this Act, then the assessing authority may, after giving such person, a reasonable opportunity of being heard, by order in writing impose on him in addition to any tax payable, a sum by way of penalty not exceeding twice the amount of tax." Section 15(2) provides that; "If the person does not, without reasonable cause, pay the tax within the time he is required, by or under the provisions of this Act to pay it, the assessing authority may, after giving such person a reasonable opportunity of being heard, by order in writing, impose upon him by way of penalty, in addition to the amount of tax and penalty under sub-section (1), a sum equal to, - (a) one and one half per cent, of the amount of tax for each month for the first three months, after the last date by which the person should have paid that tax, and (b) two per cent, of the amount of tax for each month thereafter during the time the person continues to make default in the payment of tax." As already stated, it is the admitted case of the petitioner that the entry tax has not been paid by the petitioner as per the statute. The statute cannot be complied with according to the whims and fancies of the assessee and it has to be complied with as ordered in the statute. It is well established legal principle when a thing has to be done in a particular manner it is to be done in that manner. Any other mode or manner of performance be necessarily forbidden in law. It is well established legal principle when a thing has to be done in a particular manner it is to be done in that manner. Any other mode or manner of performance be necessarily forbidden in law. The Joint Commissioner, while passing revisional order, confirming the penalty imposed under section 15(2), reduced the penalty imposed under section 15(1) to a considerable amount of Rs. 10,000 from Rs. 5,89,590. Even for reducing, that too, to such an extent, the revisional authority has given a reason taking shield in the judgment of the Supreme Court Shiv Dutt Rai Fateh Chand v. Union of India reported in [1983] 53 STC 289. In the above said facts and circumstances, I do not find any illegality or irregularity so as to interfere with the order of the Joint Commissioner. Consequently, the writ petition is dismissed. No costs.