ORDER :— The short question involved in these two appeals arises out of the decision of the High Court of Andhra Pradesh in regard to eligibility of sales-tax in respect of four items being (1) sale of Jeera, methi, ajwain, saunf and cardamom; (2) sale of wet dates; (3) sale of old newspaper; and (4) transaction of mustard oil - whether they are first purchase or not?

2. We are concerned with the assessment year 1973-74. It is not in dispute that just before the commencement of the year, by amendment of the Andhra Pradesh General Sales Tax Act oil seed has been defined in a way different for what existed prior to the amendment.

3. The High Court found against the assessee on all scores.

4. Mr. Rangam appearing in support of the appeals contended that there was a circular of Government of India with reference to the provisions of the Central Sales Tax Act as to what would be included within the meaning of oil seeds and all the five items referred to here were included in the circular as being oil seeds. It is difficult for us to accept his submission that after the Act has been admended reliance is available to be placed on the circular. On the basis of the test indicated by this Court