YASHWANT VARMA,J. - (1.) Heard Shri Piyush Agrawal, learned counsel for the revisionist and Shri B.K. Pandey, learned standing counsel for the State respondent.
(2.) These three revisions, though relating to different assessment years, raise the issue of exigibility to tax of coal briquettes manufactured by the assessee during the periods in question.
(3.) The submission of Shri Agrawal, who has appeared for the revisionists, was that the assessee was importing coal from outside the State of U.P. and thereafter selling coal briquettes within the State. In his submission since there was no distinction between coal and coal briquettes, there could have been no levy of tax on coal briquettes on their sale within the State of U.P.;