SHELAT, C.J. - The short question which arises in this reference is whether a sale of 'vatkas' (utensils) of stainless steel would be covered by entry 20 in Schedule E to the Bombay Sales Tax Act, 1959. That entry, as it stood at the material time, read as follows :-

"Stainless steel articles (other than those used as parts of industrial machinery or plant)."

The question arises out of an application made by the assessee-opponents to the Deputy Commissioner of Sales Tax under section 52 of the Act by which the assessees desired to have determination on the question as to what would be the rate of tax on the sales of stainless steel utensils purchased from a dealer residing outside the State of Gujarat. The contention of the assessees was that utensils made from stainless steel would not fall under entry 20 but would fall under the residuary entry 22 of Schedule E to the Act. The Deputy Commissioner held that such utensils would fall under entry 20 of Schedule E, observing that the word "articles" occurring in what entry was sufficiently wide enough to include utensils manufactured out of stainless steel. He observed that the Legislature, no doubt, had used in entry 2 of Sc