M. C. AGARWAL, J. - (1.) This revision petition under section 11 of the U. P. Sales Tax Act is directed against an order dated March 17, 1989, passed by the Sales Tax Tribunal whereby it allowed, in part, the dealer's second appeal for the assessment year 1980-81. I have heard the learned Standing Counsel and the learned counsel for the dealer-respondent. The dealer-respondent is a manufacturer of pullovers and cardigans from acrylic and cashmilon yarn. The question arising in the present revision is whether such cardigans and pullovers are to be treated as unclassified goods as contended by the Revenue, or as readymade garments as held by the Tribunal. By a Notification dated May 30, 1975, issued under section 3-A of the U. P. Sales Tax Act, 1948, the Government of Uttar Pradesh notified the rate and point of taxation in respect of several classes of goods which have been detailed in a Schedule appended thereto. Item Nos. 2 and 5 in the said Schedule read as under : " 2. All kinds of ready-made garments (except woollen garments) including ties, bows, mosquito nets, unfilled razais, lihafs or pillow covers. " " 5. Hosiery made of pure cotton. " As is evident from the entries, quoted above, all kinds of readymade garments except woollen garments have been classified as one item and hosiery made of pure cotton has been classified separately though it has not been specifically excluded from the scope of readymade garments. This notification was partially amended by another Notification dated April 14, 1977, which did not touch item No. 2 relating to readymade garments, but reduced the rate of tax in respect of hosiery made of pure cotton and added another item at serial No. 32 as hosiery of all kinds other than pure cotton hosiery. This new item was prescribed to be taxed at the rate of 5 per cent. The result of the amendment was that readymade garments under item No. 2 and hosiery of all kinds other than pure cotton hosiery were taxable at the same rate of 5 per cent. Lastly, by a Notification dated March 1, 1979, the Notification dated May 30, 1975, was again amended deleting from the Schedule item Nos. 3 and 32. The result of this notification was that item No. 5, i. e. , hosiery made of pure cotton remains untouched while item No. 32 hosiery of all kind other than pure cotton hosiery stood deleted from the Schedule. The contention of the department is that pullovers and cardigans are hosiery articles and since they are not made of pure cotton, they are taxable as unclassified items. The contention of the dealer, on the other hand, was that pullovers and cardigans still fell in the description of the readymade garments and were, therefore, taxable at the rate prescribed therefor. This contention has been accepted by the Tribunal. The controversy thus is only whether pullovers and cardigans can be described as garments or not. That they are readymade is not in dispute. "garment" means a dress or an article of clothing. "clothing" on the other hand, means garments in general. Therefore, clothing and garments are synonymous. There is no doubt and dispute that pullovers and cardigans are used as dress or clothing. Therefore, they are garments as we all understand it, and there can be no reason why they should not fall within the description of the "readymade garments" as contained in item No. 2 of the Schedule appended to the Notification dated May 30, 1975. Any item of hosiery intended for use as a human dress or clothing will also fall under item No. 2 in which the Government has not put any words to exclude items of hosiery from the scope of "readymade garments". As a matter of fact, hosiery made of pure cotton would fall under item No. 2 as well, but since hosiery made of pure cotton has been made taxable at a lower rate of 3 per cent, it will have to be taxed at that of 5 per cent prescribed for "readymade garments" though items of hosiery are also "readymade garments". In Laxmi Stores v. Sales Tax Officer [1983] 53 STC 244; 1982 UPTC 425, a Division Bench of this Court took the view that an item of hosiery is also a garment and that before a garment can be treated as an item of hosiery, it must satisfy two tests, i. e. , it must be worn next to the skin and must be machine-knitted. This judgment clearly shows that an item of hosiery falls under the description of a garment as well. In Commissioner of Sales Tax v. Har Narain Moti Lal 1983 UPTC 181, a learned single Judge approved the decision of the Tribunal holding that nylon and woollen hosiery were readymade garments within the Notification dated May 30, 1975, referred to above. In that case also, the Commissioner of Sales Tax had contended that they should be taxed as an unclassified item and his contention was repelled. In view of the above discussion, the Tribunal has rightly held that the pullovers and cardigans manufactured and sold by the dealer-respondent are "readymade garments" and their sale is taxable as such. This revision, therefore, has no force and is hereby dismissed. Petition dismissed. .;