PANIGRAHI, C. J.

( 1 ) THIS application comes before us on a reference made by, the Revenue commissioner under Section 24, Orissa Sales Tax Act (Act 14 of 1947 ). The questions referred to us for opinion are the following:

" (1) Whether the Maharaja of Jeypore in leasing out the right 'to cut and remove timber and collect forest produce is a 'dealer' under Clause (c) of section 2, Orissa Sales Tax Act? (2) Whether the transactions evidenced by leases, a copy of which is oh record, of the right to cut and remove timber and collect forest produce, amount in law to lease of immovable property? (3) Whether the royalty and seigniorage payable under the lease constitute 'rent' or 'price'? (4) Whether the trees and forest produce is moveable property coming under the definition of 'goods' under the Orissa Sales Tax Act or is immovable property?"

( 2 ) THE Maharaja of Jeyppre owns extensive forest areas and gets a large income from forest produce. He keeps a depot where timber and other forest produce are sold, and this business is run by the Chief Forest Officer of the Jeypore samasthanam. The officer holds a Dealer's Registration Certificate, No. KO--434 and pays sales tax under the Act.