Judgment

JASWANT SINGH, J.:- This appeal by certificate which is directed against the judgment and order dated February 20, 1970, passed by the High court of Judicature at Allahabad in writ petition No. 2943 of 1969 raises tow interesting questions viz. (1) whether carbon paper is paper falling within the purview of the word paper as used in serial No. 2 of Notification No. ST-3124/X-1012 (4)-1964 dated July 1, 1966, issued by the Governor of Uttar Pradesh in exercise of the power vested in him under Section 3-A of the U. P. Sales tax Act, 1948 (U. P. Act No. XV of 1948) so as to be liable to sales tax at the point and at the rate specified in the Schedule to the Notification and (2) whether ribbon is an accessory or a part of the typewriter.

2. It appears that the respondent which is a company incorporated under the India companies Act dealing in carbon paper, typewriter ribbon, stapler machines and stapler pins, despatches the said goods from its head office at Bombay to its branch officer at Kanpur wherefrom sales thereof are effected in the State of Uttar Pradesh. During the course of the assessment proceedings for the assessment year 1966-67, the respondent claimed that carbon p