JUDGMENT

KULDIP SINGH, J.:—The short question for our consideration in this appeal is whether a sugarcane crusher (kohlu) is an "agricultural implement" within the meaning of U. P. Government notification dated November 14, 1980 and as such is exempt from levy of Sales Tax.

2. M/s. D. H. Brothers Pvt. Ltd., a registered dealer under the U. P. Sales Tax Act, is engaged in the sale of machinery including sugarcane crushers. After coming into force of the Uttar Pradesh Sales Tax Act, 1948 (hereinafter called the Act) the State Government issued a notification dated June 7, 1948 exempting agricultural imple- ments from the levy of sales tax. Thereafter fresh notifications were issued from time to time. The relevant notification dated November 14, 1980 enumerated the "Agricultural implements" as under:

"Agricultural implements" worked by human or animal power, including Khurpi, Dibbler, Spade, Hansia (Sickle), Garden Knife, Axe, Gandasa, Chaff Cutters, Shears, Secateurs, Rake, Shovel, Ploughs, Water lifting leather buckets (Pur and Mhot), Rahat and Persian Whell, Chain Pump, Harrows, Hoes, Cultivators, Seed Drills, Threshers, Shellers, Winnowing fans, Paddy weeders, Garden fork, Lopper, B