UNTWALIA, C. J.

1. This is a reference under section 33 (1) of the Bihar Sales Tax Act, 1959 (Bihar Act 19 of 1959), hereinafter called the Act, by the Commercial Taxes Tribunal, Bihar, on the following two questions of law :

2. " (1) Whether all or any of the articles, namely, blank registers, exercise books, letter-pads, labels, loose printed forms are exempted from special sales tax as coming within the purview of the word books under item No.18 of Schedule III of Notification No. STGL-AR-107/59-9134 F. T. dated the 1st July, 1959

3. (2) Whether on a proper construction of item No.2 in Notification No. STGL-11687 F. T. dated the 27th August, 1959, all or any of the articles, namely, blank registers, exercise books, letter-pads, labels, loose printed forms, envelopes, cards, flat files are paper and as such exempt from payment of special sales tax ?"

4. The assessee is a press carrying on business under the name and style of Minerva Printing Works. It deals in printing and selling of printed articles and stationeries. The assessee returned a gross turnover of Rs.3,37,417 and claimed various exemptions to the tune of Rs.2,75,585.

5. Exemption to the tune of Rs.29,526 was a