RAJU, J.

The State has filed the tax case challenging the order of the Tribunal in so far as the Tribunal held that "hessian lined paper" manufactured and sold by respondent-assessee does not come within the description of the entry 117 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959.

2. The respondents-assessees are dealers in waterproof paper, wax paper, kraft paper and other general shop books, at Virudhunagar. For the assessment year 1978-79, as against the total and taxable turnover returned by them in their returns, the assessing officer, after verification of their accounts and after giving due and sufficient opportunity, determined the total and taxable turnover at Rs. 79, 85, 071 and Rs. 68, 24, 577, respectively. The turnover of Rs. 1, 08, 549 related to the first sales of hessian rolls with further addition for certain defects, the same was subjected to levy at 8 per cent treating the sales as representing the turnover relating to paper within the meaning of entry 117 of the First Schedule to the Act.

3. The respondents-assessees filed an appeal before the Appellate Assistant Commissioner challenging several items of turnover including the on