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Issues: Whether section 28(2) of the Andhra Pradesh General Sales Tax Act, 1957 authorised the Sales Tax authorities to keep a continuous watch and exercise supervision over the petitioners' hotels throughout the business day.
Analysis: The provision permitted inspection of accounts, registers, documents, goods, and business premises at all reasonable times. The Court distinguished between "inspection" and "watch", holding that inspection denotes careful scrutiny for a reasonable period, whereas watch implies constant observation and surveillance. The expression "at all reasonable times" was held to contemplate visits at reasonable intervals suited to the nature and hours of the business, not uninterrupted monitoring from opening to closing time. The continuous presence of inspectors for long hours over several days was therefore beyond the statutory power and amounted to harassment rather than lawful inspection.
Conclusion: Section 28(2) did not authorise continuous watch or supervision over the hotels; the petitioners were entitled to relief.