R.R.Misra, J. - (1.) All these 17 revisions filed by the Commissioner, Sales Tax, U.P., against the provisional assessment orders for the various months of the years 1985 to 1987 raise a common controversy and are directed against two consolidated orders each dated 2nd April, 1988 passed by the Sales Tax Tribunal in regard to the same assessee.
(2.) During the said years in question the assessee manufactured safety razor blades at Ghaziabad. The dispute between the parties centres round the rate of tax at which the safety razor blades manufactured by the assessee are liable to be taxed. According to the department the said razor blades are to be taxed at the rate of 12 per cent as stainless steel item but according to the assessee since the said blades are not stainless steel items, the same are unclassified items and to be taxed at the rate of 8 per cent.
(3.) I have heard the learned Standing Counsel appearing on behalf of the Commissioner, Sales Tax. In the impugned order, the Sales Tax Tribunal has stated as follows : Moreover, the magnetic test was carried out and it was found that the said blades were susceptible to magnetic test and rust also.;