The judgment of the Court was delivered by

PATHAK, J.- The respondent manufactures the bodies of motor vehicles employed as trucks and sells them. In assessment proceedings for the assessment year 1956-57 the Sales Tax Officer determined the turnover of such bodies at Rs. 16,000 and, treating them as component parts of motor vehicles within the meaning of item No. 24 of Notification No. S.T.-905/X dated 31st March, 1956, issued by the State Government under section 3-A of the U.P. Sales Tax Act, computed the tax liability by applying the rate of one anna per rupee. The respondent preferred an appeal contending that a body mounted on the chassis of a motor vehicle was not a component part of the motor vehicle and, therefore, was not an item classified in the aforesaid notification. It should be considered, he urged, as an unclassified item liable to tax at the lower rate mentioned in section 3 of the U.P. Sales Tax Act. The contention found favour with the Judge (Appeals) Sales Tax and he allowed the appeal. The Commissioner of Sales Tax applied in revision and the Judge (Revisions) Sales Tax has dismissed the revision application. At the instance of the Commissioner, the J