( 1 ) THE respondent (assessee) manufactured woollen felt. It was a dealer registered under the central Sales Tax Act as also the M. P. General Sales Tax Act. Under the provisions of Section 42-B of the State Act the assessee had asked for an opinion. Thereunder, if any question is raised by a dealer in respect of the rate of tax on any goods, the Commissioner is required to make an order determining that rate and the order passed by the Commissioner is binding on the taxing authorities in all the proceedings under the State Act, except appeals. Pursuant to the assessees request the Commissioner, on 7/8/1971, opined that the felt submitted by the assessee, being a woollen fabric, was exempt from tax under the State Act. Accordingly, for the Assessment Years 1971-72 to 1977-78, the assessee was not assessed to sales tax.

( 2 ) THIS court, in Union of India v. Gujarat Woollen Felt Mills came to the conclusion that felt such as that manufactured by the assessee was liable to excise duty. Based upon the judgment, the Commissioner, on 4/3/1982, wrote to the assessee that the clarification given to it in the letter dated 7/8/1991 was cancelled. The assessments of the assessee for the Ass