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Sales Tax Act (III of 1951)------S. 28-Assessees taxed on cotton seed but assessing authorities at time did not apply their mind to question of turn-over in respect of cotton seed oil-Section 24, in circumstances, held, applicable for re-assessment. Noorani Cotton Corporation v. Sales Tax Officer P L D 1965 ,S C 161; Messrs Pakistan Oil Mills v. The Sales Tax Officer Writ Petition No. 2003 of 1967 and Sh. Muhammad Sharif Muhammad Asghar v. The Sales Tax Officer Writ Petition No. 1881 of 1967 ref. Commissioner of Sales Tax v. Messrs Haji & Company, Chiniot P L D 1966 Lah. 256 and Rajindra Nath v. Commissioner of Income-tax A I R 1934 P C 30 distinguished. C. P. S. L. A. No. 96 of 1968 Abdur Rashid Sheikh, Senior Advocate Supreme Court (Mien Abdul Haq, Advocate Supreme Court with him) instructed by Abdul Karim, Attorney for Petitioners. Abdul Haq Sheikh, Advocate Supreme Court instructed by Iftikharuddin Ahmad, Attorney for Respondent. C. P. S. L. A. No. 128 of 1968 Abdur Rashid Sheikh, Senior Advocate Supreme Court Azimuddin Choudhury, Advocate Supreme Court with him) instructed by Abdul Karim, Attorney for Petitioners. Abdul Haq Sheikh, Advocate Supreme Court instructed by Iftikharuddin Ahmad, Attorney for Respondent. Date of hearing : 30th October 1968. JUDGMENT HAMOODUR RAHMAN, J.-The petitioners in these cases who are owners of Cotton Ginning Factories and were duly licensed under section 8 of the Sales Tax Act, 1951, were assessed for the years 1960-61 and 1961-62, respectively, to sales tax on cotton seed amounting to Rs. 46,888 and Rs. 4,912, respectively. The petitioners in Civil Petition No. 96 of 1968 were also assessed to sales tax for the year 1951-62 at Rs. 86,936. Being aggrieved by these assessments, they along with other cotton ginners filed writ petitions in the High Court of West Pakis­tan. On the ground that sales tax was not leviable even on cotton seed obtained from the ginning of own cotton under a circular of the Central Board of Revenue, issued on the 29th December 1960. These petitions were dismissed. They came up to this Court and this Court by its consolidated judgment in the case of Noorani Cotton Corporation v. Sales Tax Officer…

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