JUDGMENT

PATHAK, J.:— The short question in this appeal by special leave is whether ammonia paper and ferro paper can be described as "paper other than hand made paper" for the purposes of the notification No. ST-3124/X1012(4)-1965 dated July 1, 1966 issued under the U.P. Sales Tax Act, 1948.

2. The respondent assessee is a dealer in stationery and drawing material, and sells ammonia paper and ferro paper. In assessment proceedings under the U.P. Sales Tax Act, 1948 for the assessment year 1966-67 the assessee claimed that ammonia paper and ferro paper were liable to tax as unclassified goods at the rate of two per cent prescribed by S. 3 of the Act. The claim was not accepted by the Sales Tax Officer who held that ammonia paper and ferro paper fell under the entry "paper other than hand made paper" included in notification No. ST-3124/X-1012(4) - 1965 dated July 1, 1966 and its turnover was, therefore, liable to tax at six per cent. Against the assessment so made the assessee appealed, but his appeal was dismissed by the Assistant Commissioner (Judicial), Sales Tax. A revision petition by the assessee thereafter was dismissed by the Revising Authority. At the instance of the assess