( 1 ) THE short question for decision in the civil writ petition is whether additional demand of Rs. 35,211. 40 for sales tax in respect of the motor-bodies built by the petitioner is valid. The decision of this question would depend upon the interpretation of item I of the First Schedule of the Bengal Finance (Sales Tax) Act 1941, as extended to the Union Territory of Delhi (hereinafter called the Act), as it stood prior to the amendment of the same by notification dated the 31st August 1966. It then read as follows:-

"motor vehicles, including chasis of motor vehicles, motor tyres and tubes and spare parts of Motor vehicles. "the expression accessories was introduced after motor tyres and tubes" but before "and spare parts of motor vehicles" with effect from 1st September, 1966 by the aforesaid notification. Since the assessment in question in this writ petition deals with the period prior to the said notification of the year 1966, we are not concerned, in this writ petition, with the question whether motor-bodies would come within the expression accessories or not. We are, on the other hand, concerned only with the question whether motor bodies would come unde