JUDGMENT : 1. The matter has been heard through video conferencing with the consent of the learned counsel for the parties. They have no complaint about any audio and visual connectivity. I.A. No. 5889 of 2019 in L.P.A. No.774 of 2018 & I.A. No. 6816 of 2019 in L.P.A. No.789 of 2018 I.A. No. 5889 of 2019 has been filed for condoning the delay of 346 days in filing L.P.A. No.774 of 2018 and I.A. No. 6816 of 2019 has been filed for condoning the delay of 346 days in filing L.P.A. No.789 of 2018. 2. Heard parties. 3. Having regard to the averments made in the application and submission made on behalf of the parties, we are of the view that the appellants were prevented from sufficient cause in filing the appeal within the period of limitation. As such, the delay of 346 days in preferring both the appeals is hereby condoned. 4. I.A. No. 5889 of 2019 and I.A. No. 6816 of 2019 stand allowed. L.P.A. No. 774 of 2018 with L.P.A. No. 789 of 2018 5. Both these appeals are directed against the common order/judgment dated 15.03.2018 passed in W.P.(C) No.4483 of 2016 and W.P.(C) No. 4493 of 2015 whereby and whereunder the learned Single Judge has declined to interfere with the decision of the State Authority dated 09.10.2015 by which the writ petitioner in W.P.(C) No. 4483 of 2016 (L.P.A. No. 774 of 2018) was directed to deposit the road tax for his vehicle for period 13.03.2013 onwards as also letter dated 14.03.2014 impugned in W.P.(C) No. 4493 of 2015 (L.P.A. No. 789 of 2018) by which the writ petitioner was directed to deposit the tax to enable the authority to issue the countersignature slip. Both these appeals are being taken up together with the consent of the parties since common issues are involved. 6. The brief facts of the case which are required to be enumerated herein read hereunder as :- In L.P.A. No. 774 of 2018, the writ petitioner-respondent was granted permanent permit sometime in the year 1997 by Santhal Pargana Regional Transport Authority, Bihar for plying passenger buses for the route “Bhagalpur to Mohanpur” and renewed with effect from 13.03.2008 and thereafter, it was further renewed by State Transport Authority, Patna till 12.03.2013. The writ petitioners-respondents in L.P.A. No. 789 of 2018 was granted permanent permits by the State Transport Authority, Bihar in the year 2013/2014 for the route “Patna to Tata (JSR)”, “Patna to Chaibasa” and “Biharsharif to Ranchi” being Permit Nos. 181/2013, 182/2013, 198/2013, 199/2013 and 120/2014. In course of subsistence of the road permit, by virtue of coming into effect the Bihar Re-organization Act, 2000, the State of Bihar was bifurcated into two states i.e., the State of Bihar and successor State of Jharkhand. In consequence thereof, the permits became interstate route and in absence of counter signature in terms of the provisions of Section 88(1) of the Motor Vehicles Act, 1988, the same were not valid in the State of Jharkhand. The permits in question in W.P.(C) No. 4483 of 2016 were renewed with effect from 13.03.2008 and thereafter again renewed by the State Transport Authority, Patna till 12.03.2013. The writ petitioners, thereafter, had moved before the State Transport Authority, Jharkhand at Ranchi for its countersignature for the period from 13.03.2008 to 12.03.2013. The State Transport Authority, Jharkhand directed the writ petitioners to pay taxes with effect from the separation of the State of Jharkhand before the Taxing Authority in terms of Section 3 of the Bihar Motor Vehicles Taxation Act, 1994 (hereinafter to be referred to as the Act,1994). The writ petitioner in W.P.(C) No.4483 of 2016, during the pendency of the counter signature, had moved before this Court vide W.P.(C) No. 4492 of 2008 for quashing the order passed by the Transport Authority, Jharkhand and this Court, vide order dated 23.08.2011 directed the Authority to decide the matter within four weeks from the date of receipt of the copy of the order. In terms of the said order, representation was filed by the writ petitioner but no order was passed on his representation which led the writ petitioner to file a contempt proceeding before this Court in which a show cause was filed by the State Transport Commissioner-cum-Secretary of State Transport Authority and in the said show cause the stand inter alia was taken that the petitioner has already been granted countersigned permit for the route in question and as such, the grievance of the writ petitioners has been redressed, therefore, the contempt proceeding may be dropped and in pursuance thereof, the contempt proceeding was dropped. Subsequent thereto, the writ petitioners received notice containing therein direction to pay tax from 13.03.2013/31.12.2013 onwards on the ground that the writ petitioners were also required to pay tax for the period permit was not countersigned. The said action of the State Transport Authority was challenged before this Court by filing writ petitions being W.P.(C) No. 4483 of 2016 and W.P.(C) No.4493 of 2015. Taking into consideration the order passed by Division Bench of Patna High Court in C.W.J.C. No. 74 of 2016 wherein the Patna High Court, by taking into consideration the provision of Section 88(1) of the Motor Vehicles Act, 1988, has quashed and set aside the impugned decision of the Authority with a direction upon the concerned respondent not to realize the tax from the petitioner for the period the permits were not countersigned, learned Single Judge of this Court allowed the writ petitions directing the respondents not to realize the taxes from the petitioners for the period the permits were not countersigned. 7. Mr. Rahul Kumar Gupta, learned Sr. S.C.-I, appearing for the State-appellant has challenged the order passed by the learned Single Judge inter alia on the ground that the writ petitioners are liable for making payment of tax since the permit granted in favour of the writ petitioners were renewed up to 2018 and accordingly, road tax was fixed and when it was not paid by the writ petitioners, rightly notices were issued to them for making payment of the road tax but without taking into consideration this aspect of the matter, learned Single Judge has set aside the order hence the impugned order is not sustainable in the eyes of law. 8. Having heard the learned counsel for the State-appellant and after appreciating the grounds agitated in the present memo of appeals as also taking into consideration the findings recorded in the impugned order, this Court has found therefrom the admitted facts to the effect that the writ petitioners were granted road permits and in course of its subsistence, by virtue of bifurcation of State of Bihar, the permits became interstate which were renewed up to the year 2018. The writ petitioners moved before the Respondent Nos. The writ petitioners moved before the Respondent Nos. 2, State Transport Authority, Jharkhand at Ranchi for its counter signature for the period between 2013 to 2018 upon which the State Transport Authority, Jharkhand issued direction upon the writ petitioners to pay taxes with effect from the separation of the State of Jharkhand before the Taxation Authority in terms of the provision of Section 3 of the Act, 1994. The said decision of the State Transport Authority fell for consideration before this Court on being assailed by the writ petitioners wherein the learned Single Judge has taken into consideration the order passed by the Division Bench of the Patna High Court in C.W.J.C. No. 74 of 2016. This Court has gone across the judgment rendered by the Patna High Court passed in C.W.J.C. No. 74 of 2016 wherefrom it transpires that the Patna High Court has taken into consideration the provision of Section 88(1) of the Motor Vehicles Act, 1988, basing upon the same, it has been laid down therein that the liability of tax under the Taxation Act would, therefore, arise from the date of such countersign as clearly provided in Section 14 of the Taxation Act because only from the date of counter signature the interstate permit issued by the Authority from outside the State of Bihar would be valid within the State of Bihar. We have also considered the provision of Section 88 of the Motor Vehicles Act, 1988 whereby and whereunder the validation of permits for use outside region in which granted except as may be otherwise prescribed, a permit granted by the Regional Transport Authority of any one region shall not be valid in any other region, unless the permit has been countersigned by the Regional Transport Authority of that other region, and a permit granted in any one State shall not be valid in any other State unless countersigned by the State Transport Authority of that other State or by the Regional Transport Authority concerned. For ready reference, the provision of Section 88(1) of the Motor Vehicles Act, 1988 is reproduced hereinbelow :- “88. For ready reference, the provision of Section 88(1) of the Motor Vehicles Act, 1988 is reproduced hereinbelow :- “88. Validation of permits for use outside region in which granted.- (1) Except as may be otherwise prescribed, a permit granted by the Regional Transport Authority of any one region shall not be valid in any other region, unless the permit has been countersigned by the Regional Transport Authority of that other region, and a permit granted in any one State shall not be valid in any other State unless countersigned by the State Transport Authority of that other State or by the Regional Transport Authority concerned.” It is thus evident that from the provision of Section 88(1) of the Motor Vehicles Act, 1988 that a permit granted in one State shall not be valid in another State, unless the same is countersigned by the State Transport Authority of the other State. Section 14 of the Act, 1994, which is a non-obstante provision, further mandates that no vehicle on the permit granted by the other State under the provisions of the Motor Vehicles Act, 1988 shall be used or kept for use in other State unless the tax calculated at the appropriate rate specified in Schedule-I and additional motor vehicles tax as specified in Schedule-II for the entire period for which the permit is valid for the other State are paid. 9. On conjoint reading of the provisions of Section 88(1) of the Motor Vehicles Act and Section 14 of the Act, 1994 it would be evident that for entering the territory of the State of Jharkhand out of interstate permit, if any permit holder wants to ply the vehicle in the State of Jharkhand, the same is required to be countersigned by the concerned State Transport Authority of the State of Jharkhand on payment of tax at the appropriate rate specified and as such, in the absence of any countersignature, the writ petitioners’ vehicles could not have entered in the territory of State of Jharkhand and, therefore, the State Transport Authority, Jharkhand will have no authority to realize the tax from the date of issuance of the primary permit by the State of Bihar. 10. 10. This Court, after taking into consideration the applicability of the provision of Section 88(1) of the Motor Vehicles Act, 1988 along with Section 14 of the Act, 1994 as also the judgment rendered by the Division Bench of the Patna High Court in C.W.J.C. No. 74 of 2016, has come to the conclusion that the State Authority has committed illegality in taking decision by raising demand upon the writ petitioners for making payment of tax by virtue of issuance of the impugned orders and as such, the learned Single Judge is right in interfering with the impugned decisions by quashing and setting the same aside. Accordingly, we are of the view that the order passed by the learned Single Judge requires no interference. 11. In the result, both these appeals fail and are dismissed. 12. Consequently, I.A. No. 5890 of 2019 [in L.P.A. No. 774 of 2018] and I.A. No.6817 of 2019 [in L.P.A. No. 789 of 2019] filed for stay of the operation of part of the impugned order/judgment dated 15.03.2018 also stand dismissed.