CHARANJIT TALWAR, J.

The petitioner herein, firm Dassmal Ram Labhaya of Loha Mandi, Motia Khan, Delhi, had sought exemption of the sales tax on the sale of Persian wheel frames manufactured by it for the assessment year 1965-66. The Sales Tax Officer dismissed its plea and held that it was not entitled to the exemption of the sales tax on the sale of the Persian wheel frames amounting to Rs. 3,05,227.00, on the ground that the said goods manufactured and sold were not agricultural implements. The petitioner appealed against the said order which appeal was dismissed by the Assistant Commissioner, Sales Tax. Thereafter, the first revisional authority as well as the second revisional authority also dismissed the respective revision petitions. A copy of the order dated 15th December, 1970, of the Financial Commissioner is annexure "D" to the writ petition. By the present petition the challenge is to the orders of the assessing authority on the ground that the Persian wheel frames sold by the petitioner is an agricultural implement and a such was exempted boy item 29 of the Schedule to the Bengal Finance (Sales Tax) Act, 1941, as extended to the Union Territory of Delhi (herein