ORDER

1. These appeals are directed against the common judgment and order passed by the High Court of Rajasthan in S.B. Civil Sales Tax Revision No. 932 of 2002 and connected matters, dated 23.01.2003. By the impugned judgment and order, the High Court has opined that 'surgical cotton' is a commercially different commodity from 'cotton' and accordingly confirmed the order passed by the Rajasthan Tax Board, Ajmer in Appeal Nos. 509 to 512 of 2001, dated 28.06.2002.

Facts:

2. The appellant is a partnership firm registered as a dealer both under the Rajasthan Sales Tax Act, 1994 (for short, 'the Act') and the Central Sales Tax Act, 1956 (for short, 'the CST Act'). The appellant carries on the business of processing the cotton and transforming it into surgical cotton.

3. The assessment years in question are 1992-93 to 1998-99. The assessee purchases cotton after paying tax at the rate of 4% and thereafter process it into surgical cotton for sale.

4. For the relevant assessment years, the assessing authority had conducted a survey on the business premises of the assessee and opined that surgical cotton produced and sold by the assessee is a separate commercial commodity from cotton and thus