The judgment of Court was delivered by

KANIA, J. - This is a reference under section 61(1) of the Bombay Sales Tax Act, 1959 (hereinafter referred to as "the said Act"). The questions referred to us for our determination are as follows :

"(1) Whether the Tribunal was correct in law in holding that the printer wrappers sold by the applicants could be said to be covered by the words 'paper adapted for use in packing goods' within the meaning of entry 6 of Schedule C to the said Act ?

(2) Whether the Tribunal was justified in disallowing the sales of Rs. 2,86,061 even though the applicant satisfied that the buyer is a recognised dealer and has issued the required certificate in form 15 and that the goods purchased by him were specified in his recognition certificate ?"

The relevant facts giving rise to this question are as follows : The applicants are registered dealers and are running a printing press. They supplied packing labels to Parle Products Private Limited (hereinafter referred to as "Parle Products") against certificate in form 15. Parle Products are also registered dealers and had obtained a recognition certificate as provided under section 25 of the said Act, as i