ORDER These appeals are directed against an order of the Rajasthan High Court dismissing the petitions filed by the appellant (Commercial Taxes Officer, Circle A, Kota), requesting the High Court to direct the Board of Revenue, Rajasthan at Ajmer, to state a case for the opinion of the High Court under Section 15(3A) of the Rajasthan Sales Tax Act, 1954. The High Court by its order dated July 5, 1979 held, while dismissing the said applications, that the respondent cannot be said to have acted deliberately in contravention of law without any reasonable excuse in undertaking on job basis the work of processing goods belonging to other dealers meant for sale. At the same time, the High Court declined to express any opinion on the correctness or otherwise of the interpretation placed by the Board on Section 8(3)(b) of the Central Sales Tax Act.
Since these matters pertain to levy of penalty and having regard to the facts and circumstances of the case and the findings recorded by the High Court, which could not be challenged successfully before us, no interference is called for. Accordingly, civil appeals are dismissed.