The judgment of the Court was delivered by

SUJATA V. MANOHAR, J. - The respondents in both these references, M/s. Gordhandas Tokersey are registered dealers under the provisions of the Bombay Sales Tax Act, 1959. The respondents filed two applications both dated 17th August, 1970, before the Commissioner of Sales Tax under the provisions of section 52 of the Bombay Sales Tax Act, 1959, for the determination of the correct rate of tax payable on the sales of sandalwood and sandalwood oil effected by the respondents under their invoices Nos. 1958 and 1850 dated 6th August, 1970 and 18th April, 1970, respectively. It was the contention of the respondents that sandalwood and sandalwood oil were governed by the residuary entry 22 of Schedule E to the Bombay Sales Tax Act, 1959. The Commissioner of Sales Tax, however, held that sandalwood and sandalwood oil were perfumes within the meaning of that word in entry 19 of Schedule E to the Bombay Sales Tax Act, 1959, and were liable to tax accordingly. From these decisions the respondents preferred appeals before the Sales Tax Tribunal being Appeals Nos. 3 and 4 of 1971. The Tribunal, by its common judgment in both the appeals dated