MEHTA, J., delivered the following judgment on July 8, 1968.

The short question which has been referred to us is :-

"Whether on the facts and in the circumstances of the case the sale of corrugated sheets by the opponent-firm was covered by entry 80 of Schedule B or entry 15 of Schedule B to the Bombay Sales Tax Act, 1953, prior to its amendment by Bombay Act 16 of 1957 ?"

The short facts which have given rise to this reference are :-

The opponent-firm is a registered dealer dealing in iron and steel, gold and silver, vegetable ghee, corrugated iron sheets etc. It was assessed according to best judgment for the period from 1st April, 1956, to 31st March, 1957, by an order passed by the Sales Tax Officer, Godhra, on 30th June, 1962. The assessee appealed to the Assistant Commissioner of Sales Tax which was dismissed and its revision was only partially allowed by the Deputy Commissioner of Sales Tax. The Deputy Commissioner held that entry 15 of Schedule B relating to iron and steel only included primary products of the rolling mills which are not subjected to any process after rolling and, therefore, corrugated sheets were covered by entry 80 of Schedule B to the Act. In re