Judgment

HEGDE, J.:- This is an appeal by certificate. The only question that arises for decision is whether groundnut is oilseed. The High Court has come to the conclusion that the groundnut is oil-seed. The question as to the nature of groundnut came up for consideration in connection with the levy of purchase tax on the purchase of oil-seed. The assessee in this case is a manufacturer of oil and the assessee appears to have purchased groundnuts in large quantity for the manufacture of oil. He contended before the assessing authorities as well as before the High Court, unsuccessfully, that groundnut is not oilseed. In support of, that contention, he relied on the decision of the Madhya Pradesh High Court in Commr. of Sales Tax, Madhya Pradesh, Indore v. Bakhat Rai and Co. (1966) 18 S.T.C. 285 (Mach Pra) and the decision of a Single Judge of Punjab & Haryana High Court in Hans Raj Choudhri v. J. S. Rajyana, (1967) 19 S.T.C. 489 (Punj) ). These two decisions undoubtedly support his contention. The learned Judges of the Allahabad High Court have not accepted those decisions as laying down the law correctly and we are in agreement with the view taken by the learned Judges of the Allah