Meredith, J.

1. This is a case stated by the Board of Revenue under Sec.21 (3), Bihar Sales Tax Act, 1944. The question referred is :

"Whether green-betel leaves called pan are taxable articles within the meaning of Sec. 6, Bihar Sales Tax. Act, 1944, read with Notfn. No. 7567-F, dated 8-7-1944 issued by the Government of Bihar in the Finance Department."

2. The assessees are 13 dealers in betel leaves used in making up pan. It was found that they had been importing betel leaves from outside the Province of Bihar, and had been carrying on this business for a long time, with an annual gross turnover exceeding Rs. 5000 in the case of each of them during the financial year 1943-44, but they had failed to apply for registration under Section 7 of the Act. Accordingly, the Sales Tax Officer issued notices upon them on 14-3-1945, under Sec.10 (5) of the Act calling upon them to file necessary returns for the quarter ending 31-12-1944. Instead 6f filing returns, the assessees filed objection petition on the ground that betel leaves come within the category of green vegetables and as-such were exempted from the levy of sales tax by Notfn. No. 7567 dated 8-7-1944, issued by the Gove