( 1 ) THESE two revision petitions have been preferred by the State and are directed against a common assessee and they relate to two separate assessment years. The respondent is a manufacturer of typewriter ribbons with a branch office at Bangalore. During the assessment years 1964-65 and 1965-66, it submitted returns in regard to the sales of such article. The assessee contended that it was liable to pay sales tax as per the general provision under section 5 (1) of the Mysore Sales Tax Act, 1957, at 2 per cent. of the turnover. The assessing authority sought to levy tax on the basis that the typewriter ribbons were parts of typewriters and as such fell within entry 18 of the Second Schedule to the Act. The Sales Tax Appellate Tribunal came to the conclusion that typewriter ribbons were not parts of typewriters falling under entry 18 of the Second Schedule.

( 2 ) THE question of law arising for decision is, whether typewriter ribbons fall under entry 18 of the Second Schedule or under section 5 (1) of the Act ?

( 3 ) IT is contended on behalf of the State by Sri P. K. Shyamasundar, learned Government Pleader that a typewriter cannot be operated without a ribbon