( 1. ) THIS is a reference under Section 44 (1) of the M. P. General Sales Tax Act (hereinafter referred to as "the Act") made by the Board of Revenue referring the following question of law for the opinion of this Court:

Whether under the facts and circumstances of the case, when a printer produces for a customer an article which is of value only to the particular customer, whether only the material used in producing this article or the total price of the finished article will be liable to sales tax ?

( 2. ) THE facts in brief giving rise to this reference may be stated thus : The non-applicant M/s. Ratna Fine Arts Printing Press, the owner of a printing press was assessed to tax by the Assistant Sales Tax Officer, Ujjain, for the period from 1st April, 1968, to 31st March, 1969, by his order dated 20th May, 1970. The gross turnover was determined at Rs. 18,000. The taxable turnover was also determined at the same figure and a sum of Rs. 1,260 was assessed as tax payable by the assessee. A penalty of Rs. 100 was imposed under Section 17 (3) of the Act and a penalty of Rs. 15 was also imposed under Rule 69-A. In the first appeal by the assessee before the Appellate Assistan