SINGH, J. - (1.) THE point involved in this appeal is short. THE assessee manufactures camphor, distilled turpentine oil, camphor oil, etc. It is registered as a dealer under the U.P. Sales Tax Act and under the Central Sales Tax Act. It sought the opinion of the Commissioner of Sales Tax regarding the rate of tax payable by it on these sales under the Central Sales Tax Act. THE Commissioner of Sales Tax has taken the view that only questions arising under the U.P. Sales Tax Act can be referred and answered under section 35. Thus, the only question in this appeal is as to whether an assessee can ask for the opinion of the Commissioner as regards the appropriate rate of tax imposable under the Central Sales Tax Act. THE answer to this question depends on the interpretation to be put on section 9(2) of the Central Sales Tax Act. Section 9(2) of the Central Act runs as under : "9. (2) Subject to the other provisions of this Act and the Rules made thereunder, the authorities for the time being empowered to assess, reassess, collect and enforce payment of any tax under the general sales tax law of the appropriate State shall, on behalf of the Government of India, assess, reassess, collect and enforce payment of tax, including any penalty, payable by a dealer under this Act as if the tax or penalty payable by such a dealer under this Act is a tax or penalty payable under the general sales tax law of the State; and for this purpose they may exercise all or any of the powers they have under the general sales tax law of the State; and the provisions of such law, including provisions relating to returns, provisional assessment, advance payment of tax, registration of the transferee of any business, imposition of the tax liability of a person carrying on business on the transferee of, or successor to, such business, transfer of liability of any firm or Hindu undivided family to pay tax in the event of the dissolution of such firm or partition of such family, recovery of tax from third parties, appeals, reviews, revisions, references, refunds, rebates, penalties, charging or payment of interest, compounding of offences, and treatment of documents furnished by a dealer as confidential, shall apply accordingly : Provided that if in any State or part thereof there is no general sales tax law in force, the Central Government may, by rules made in this behalf, make necessary provision for all or any of the matters specified in this sub-section." It will be seen that the wordings of section 9(2) are very wide. THE intention of the Parliament was to make the machinery provided under the State Act available for making assessments under the Central Sales Tax Act. Counsel for the assessee contended that the application moved by the assessee under section 35 is in the nature of a reference to the Commissioner in which his opinion is solicited in respect of matters set out under section 35(2) of the Act. Sri V. D. Singh, appearing on behalf of the department, however, contended that the reference referred to in section 9(2) refers to a reference made under section 11 of the U.P. Act. Section 9(2) does not in so many words describe what type of reference is contemplated by the sub-section. A reference specifically provided for under the State Act would obviously fall within the ambit of this provision. But, in view of the consideration that the Parliament intended that the entire assessment proceedings should be conducted in accordance with the State laws, it will not be appropriate to take a restricted view of the word "reference" as occurring in section 9(2) in case the proceedings under section 35 have the essential characteristic of a reference. Proceedings under section 35 start with an application by the assessee. THE Commissioner of Sales Tax expresses his opinion on the point referred. THE decision does not affect the validity of any order passed earlier by the assessing authority or the appellate or revising authority. It thus only declares the law. In a reference under the U.P. Act, the High Court expresses an advisory opinion, and declares the law on the point. Effect to the opinion is given by the revising authority later on. Thus, both in a proceeding under section 35, and in a proceeding under section 11 of the Act, the law on the point is declared, effect to which is given later on. It is undoubtedly true that in a reference answered by the High Court, the law declared operates also for that assessment year, but if the law declared is of a general nature, then it becomes binding on the sales tax authorities for the other years also. Thus, in substance, a proceeding under section 35 is really a provision in the nature of a reference made by the assessee to the Commissioner for his opinion on the question envisaged by section 35(2) of the Act. This being so, the Commissioner of Sales Tax was competent to decide the application on merits, and he erred in refusing to entertain it on the ground that the question related to liability under the Central Sales Tax Act. THE appeal is accordingly allowed with cost to the assessee, which is assessed at Rs. 200. Appeal allowed.;