(1) THE question that the High court of Madhya Pradesh was required to consider in these appeals reads thus :

"WHETHER, on the facts and in the circumstances of this case, the Board of Revenue was justified in holding that the husk of soyabean oil was liable to be taxed as the same was not covered by notification No. 1073-537-V ST dated 7-4-67 as extended from time to time and consequently it was not exempt from payment of turnover tax?"

(2) THE High court answered the question in the negative and in favour of the assessees. The State is in appeal by special leave.

(3) THE notification which we are required to consider was issued on 7/04/1987 in exercise of power conferred by Section 12 of the Madhya Pradesh General Sales Tax Act, 1958. Thereby the State exempted from the payment of tax "husk of all grains, cereals, pulses and rice."

(4) THE assessees extract oil from soyabean. In their assessment the assessing authority held that the husk of soyabeans was not exempt from the payment of tax by reason of the said notification and assessed the assessees accordingly. The assessees first appeal to the Deputy Commissioner and second appeal to the Board o