JUDGMENT

SABYASACHI MUKHARJI, J. :— Special leave granted and these appeals are disposed of by the judgment herein.

2. These appeals are from the judgments and orders of the High Court of Allababad dated 4th February, 1987 and March 26,1987 respectively. These involve a common question. The facts of the appeal arising out of Special leave Petition No. 1293 of 1988 and the facts of the appeal arising out of Special Leave Petition No. 1296 of 1988 are similar. In order to appreciate the contentions raised herein, it would be appropriate to deal with the facts of the appeal arising out of Special leave petition No. 1293 of 1988. The assessee is engaged in repairing and refilling of cotton bowls on the shafts which are used as part of calendering machine in the textile industry. The cotton bowl is a shaft made of steel on which a thick layer of cotton is pasted and affixed. It is used in the textile finishing industries as an essential part of calendering machine. In the course of its use the cotton pasted on the shaft loses its thickness and shape and after some time it requires repairing and refilling. The assessee in this case moved an application under section 35 of the U.P. Sales-t