Om Prakash, J. - (1.) These are three revisions for the assessment years 1976-77, 1977-78 and 1978-79 against the Tribunal's combined order dated 28th June, 1986.
(2.) The assessee, a registered dealer, carrying on business in certified seeds, claimed exemption in respect of the turnover of certified seeds. The exemption was allowed by the assessing officer for these years. Thereafter, the assessing officer initiated proceedings under Section 21 of the U.P. Sales Tax Act, 1948, that the exemption on the turnover of seeds was wrongly allowed. He, therefore, assessed the turnover of the seeds, said to be certified seeds by the assessee, under Section 21.
(3.) The assessee appealed to the Assistant Commissioner (Judicial) and raised two contentions: (i) that initiation of proceedings under Section 21 by the assessing officer was bad in law; (ii) that the assessee was engaged in the sale of certified seeds and, therefore, turnover of that was exempted.;