V. S. DESAI, J. - The questions raised in the present reference at the instance of the Commissioner of Sales Tax are as follows :-

"1. Whether the cotton which was subjected to process of cleaning, boiling, bleaching and drying and carding, remained as cotton after the above process ? and

2. Whether the sale of the said goods known as absorbent cotton wool falls within item 1 of Schedule B to the Bombay Sales Tax Act, 1953, as amended by Bombay Act 10 of 1954, or whether the same is liable to tax under the residuary entry covered by item 80 of the said Schedule ?"

The respondents are dealers and were at all material times registered under the Bombay Sales Tax Act, 1953. During the period from 1st April, 1954, to 31st March, 1955, the respondents had effected sales of absorbent cotton wool of the value of Rs. 2,23,475-6-2. In their assessment for the said period, these sales were held by the Sales Tax Officer as taxable under item 80 of Schedule B to the Bombay Sales Tax Act, 1953, and not under item 1 of the said Schedule as contended by the respondents. The Assistant Collector of Sales Tax in appeal upheld this view of the Sales Tax Officer, and the Additional Collector o