K. SHIVASHANKAR BHAT, J.

( 1 ) THE dealer is the petitioner in both these revision petitions, under the provisions of the Karnataka Sales Tax Act, 1957 ("the Act", for short ). These petitions pertain to the assessment years 1981-82 and 1982-83. The question is regarding the scope of section 18a of the Act.

( 2 ) THE petitioner is the dealer in grey iron rough castings. Till the year 1980-81 this was taxed under the Act, under section 5 (1), that is to say the goods in question did not fall within any of the enumerated goods under various Schedules to the Act. The petitioner was collecting the tax from its customers according to law. In August, 1982, the petitioner entertained a doubt about the rate of tax applicable to the goods in question and sought clarification from the assessing authority. However there was no response from the assessing authority to this letter. But, in respect of the assessment year 1982-83 he made an assessment in November, 1982, treating the goods as falling under section 5 (1 ). The petitioner filed an appeal contending that the goods in question came under entry 2 of the Fourth Schedule to the Act. This was accepted by the appellate authority and hence

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