ORDER G. S. SINGHVI, J. Having failed to persuade Joint Commissioner (CT), Legal, Hyderabad (respondent No. 3) to entertain its prayer for stay of the demand of tax, the petitioner has invoked the jurisdiction of this court under article 226 of the Constitution of India. The petitioner is a private limited company. It is engaged in the manufacture and sale of rubber products and adhesives. It has manufacturing units at Gudur in Andhra Pradesh and at Ponneri and Athipetti in Tamil Nadu. For assessment year 2001-02, the petitioner claimed exemption under section 6A of the Central Sales Tax Act, 1956 (for short, "the Central Act") to the tune of Rs. 2,08,93,930 by asserting that it had transferred the stock of rubber products and adhesives manufactured in the regular course of business to its branches outside the State for being used in the execution of work contracts and the branches had also effected intra-State sales of a portion of the rubber products and adhesives received by way of stock transfer after paying the local taxes due on such sales. By an order dated February 18, 2003, respondent No. 1 accepted the petitioner's claim for exemption. After two years and six months, Deputy Commissioner (CT) (respondent No. 2), Nellore issued notice dated August 29, 2005 to the petitioner proposing to make reassessment under section 9(2) of the Central Act by withdrawing exemption valued at Rs. 2,08,93,930. The reasons which prompted respondent No. 2 to issue notice for reassessment were :