Bharati Sapru, J. - (1.) HEARD learned counsel for the revisionist Shri Piyush Agarwal and Shri B.K. Pandey, learned Standing Counsel for the State. This revision has been filed under Section 11 of the U.P. Trade Tax Act for the assessment year 1986-87 against the order passed by the Tribunal dated 22.12.2000. By this order, the Tribunal has remanded the matter to the assessing authority for limited purpose to ascertain as to what was the number of woolen goods/garments, which are to be taxed as an unclassified item. The question of law referred to is as hereunder.:- (i)Whether in view of the judgment of this Hon'ble Court in the cases of Commissioner Sales Tax Vs. Super Wool House (1995 U.P.T.C. Page 378) and Commissioner Sales Tax Vs. Har Narain Moti Lal (1983 U.P.T.C. Page 181), the Trade Tax Tribunal was justified in remanding the matter to the assessing authority.? (ii)Whether in view of the facts and circumstances of the case, the Trade Tax Tribunal was justified in holding that the pullovers and cardigans made out of acrylic and nylon which were sold by the applicant are different and readymade garments of wool.? (iii)Whether in view of the facts and circumstances of the case, the Trade Tax Tribunal was justified in allowing the appeal of the Revenue and remanding the matter to the assessing authority.? The facts of the case are that the assessing authority passed an assessment order on 26.7.1989 and accepted all the contentions as raised by the assessee but raised dispute with regard to the purchase of ready made woollen garments, which he said were to be taxed as an unclassified item, at a higher rate of 6% or 8%. Aggrieved by the assessment order, the assessee filed an appeal under Section 9 of the Act. The First Appellate Authority, by its order dated 30.4.1990 allowed the appeal of the applicant but placed reliance upon the judgement of this Court as reported in 1983 U.P.T.C.181 in Commissioner of Sales Tax Vs. Har Naraini Moti Lal. By this judgement, the Court had held that Nylon and woollen hosieries were ready made garments and both were liable to be taxed as hosieries under Notification No. 4949 dated 30.5.1975 and notification No. 5785 dated 12.9.1981. Aggrieved by the order of the First Appellate Authority, the Revenue filed a Second Appeal under Section 10 of the Act. The Trade Tax Tribunal by impugned order dated 22.12.2000 has allowed the appeal of the Revenue and has remanded the matter to the Assistant Commissioner as stated earlier, for the limited purpose of finding out the number of woolen garments that were also purchased and sold. The notification is as given below. :- That notification No.4949 of 30.5.1975 as classified at Serial No.2 is given below:- "2 All kinds of ready made garments (except woolen garments) including M or I 5percent ties, bows, mosquito nets, unfilled razais, lihafs or pillow covers. That thereafter by notification No.5785 dated 7.9.1981, the relevant entry No.4 and 23 are quoted below.: S.No. Description of goods Point of taxRate of tax 4. All kinds of ready made garments(except woolen M or I 6 percent garments)including ties,bows, mosquitto nets, unfilled razais, lihafs or pillow covers. 23. Hosiery made of pure cotton M or I 4 percent That thereafter by notification No.6561 dated 12.9.1986, the entry with regard to ready made garments were amended and the only rate of tax was reduced to 4% instead of 6%. The relevant entry is quoted below: S.No. Description of goods Point of tax Rate of tax 4.All kinds of ready made garments (except woolen garments) including M or I 4 percent ties, bows, mosquito nets, unfilled razais, lihafs or pillow covers." From the above notifications, it is abundantly clear that although there is no difficulty in understanding that the word 'garment' and 'hosiery' are interchangeable, the words 'wool' and 'cotton' are not interchangeable, nor is wool interchangeable with 'nylon' or 'acrylic'. The entries made in the Notification referred to of ready made garments but exclude woolen garments, i.e., to say that garments made out of wool have been specifically excluded from the entry. It stands to reason. Cotton is a product extracted from plants. Nylon and synthetic fibers are artificially manufactured yarns, whereas wool is a natural product, extracted from animals. When woolen garments have been excluded from the entry, there can be no doubt that they stand outside this entry because woolen garments have not been notified at any other place, specifically, they have rightly been construed to be an unclassified item to be taxed at 6% or 8%. I have heard learned counsel for both the sides at length and I have also perused the above notifications. Learned counsel for the revisionist very strenuously argued that garments and hosieries are interchangeable and, therefore, in view of certain decisions of this Court, woollen garments are also garments and, therefore, should be reckoned under the entries of all kinds of ready made garments. However, in view of the discussions made above, it is difficult to accept the contention of the learned counsel for the assessee that even though woolen garments are specifically excluded from the entries from whose benefits he seeks, simply because they are garments and they should be treated to be covered under the entry No.4 of the Notification dated 7.9.81. Clearly, as stated earlier, wool is completely different from cotton. The arguments of learned counsel for the assessee are, therefore, rejected. The view taken by the Tribunal is correct. I see no reason to interfere in the order passed by the Tribunal. The questions are thus, answered in favour of the Revenue and against the assessee. This revision is devoid of merits and is, therefore, dismissed.;