( 1 ) THESE sales tax references Nos. 368 to 377 of 1953 are connected and have been heard together. In all these ten cases the question referred to this Court for opinion by the Judge (Revisions) Sales Tax is :whether linseed oil is edible oil within the meaning of notification No. S. T. 117/x-923/1948, dated 8th June, 1948?

( 2 ) THIS question has been referred to us as the dealers concerned with these ten references are all dealers in linseed oil and the question arose whether tax on their turnover in respect of linseed oil was to be calculated at the rate applicable to edible oils or at the rate applicable to non-edible oils in view of the notification referred to in the question. The Sales Tax Officer who first made the assessment held that linseed oil is a non-edible oil. The Judge (Appeals) Sales Tax came to the view that linseed oil is edible oil and for this purpose he relied mainly on the Report on the marketing of Linseed in India, 1938 Edition, published by the Manager of Publications, Delhi. The Judge (Revisions) disagreed with the Judge (Appeals) Sales Tax and held that linseed oil is non-edible oil. In giving his decision in the various revision applic