K.S.Hegde, J. (1) THIS appeal by special leave arises from a judgment of the High court of Calcutta in a reference made to it under Suction 21 (J) of the Bengal Finance (Sales Tax) Act, 1941 (Act VI of 1941). That was a reference made by the Board of Revenue, West Bengal in pursuance of the directions given by the High court. After stating a case. the Board referred three questions to the High court at the instance of the assessee company. The assessee informed the High court that it did not want any answer to the third question. The High court answered questionsNos. (i) and (ii) in favour of the asscssue company. Aggrieved by that order the Board of Revenue has come; up in appeal to this court. (2) THE rnaterial facts are these: MESSRS. Phelps & Co. (P) Ltd. the assessee is a company ircported under the Indian Companies Act, 1913 having its Registered Oflicc in New Delhi. It is carrying on business, amongst other places, at Calcutta. It was registered as a dealer under the Bengal Finance (Sales Tax) Act, 1941 and was carrying on the business of tailors, drapers, out-fitters and industrial "gloves manufactures. (3) IN respect of the assessment for the four quarters ending on 31/03/1957 the said dealer in its claim for exemption under S. 5 (2) (a) (ii) of the Act, included the following transactions : (1) Sales to Messrs. The Indian Iron and Steel Go. Ltd. for Rs. 51,554-8-0. (2) Sales to Messrs. Indian Standard Wagon Go. Ltd. for Rs. 20,150-1-0. (3) Sales to Messrs. The Hoogly Docking & Engineering Go. Ltd. for Rs. 546-2-0. The Commercial Tax Officer, Esplanade Charge, who assessed the dealer found that the above transactions related to the sales of different types of hand gloves which the purchasing dealers purchased for the purpose of the same being used by their workers while being engaged in work in the factories. He by his order, dated 4/12/1957 observed that the purchase of hand gloves could not be called as being required for the purpose of manufacture of goods for sale, and, accordingly, disallowed the dealers claim for exemption of Rs. 72,250-11-0. That order was affirmed by.the Assistant Commissioner of Commercial Taxes in appeal as well as by the Board of Revenue. He by his order, dated 4/12/1957 observed that the purchase of hand gloves could not be called as being required for the purpose of manufacture of goods for sale, and, accordingly, disallowed the dealers claim for exemption of Rs. 72,250-11-0. That order was affirmed by.the Assistant Commissioner of Commercial Taxes in appeal as well as by the Board of Revenue. Thereafter the assessee company filed a petition under S. 21(1) of the Act asking the Board of Revenue to refer certain questions of law to the High court. The Board refused to refer those questions. Dissatisfied by the order of the Board, the dealer moved the High court of Calcutta under S. 21 (2) of the Act for direction to the Board to state a case. The High court accepted that petition and directed the Board to state a case and submit the questions that the assessee company wanted it to submit to the High court. The Board accordingly stated a case and submitted the following three questions : (I) "Whether "gloves put on by the purchasing Companies workmen engaged in hot jobs or in handling corrosive substances in the course of manufacture can be stated to have been used in the manufacture of goods for sale as understood by the provisions of S. 5(2)(a)(ii) of the Bengal Finance (Sales Tax) Act, 1941. (II) Whether the item "mill stores appearing in the certificate of registration of the Indian Iron & Steel Company Ltd., covers "gloves. (III) Whether a selling dealer claiming exemption under S. 5(2)(a)(ii) of the Bengal Finance (Sales Tax) Act, 1941 read with Rule 27-A of the Bengal Sales Tax Rules, 1941 is required to ascertain after receipt of a declaration in Statutory form No. XXIV from a purchasing registered dealer if the tatters certificate of registration covers the goods purchased." (4) AS mentioned earlier the assessee company did not want the High court to answer No. (iii). Hence it is not necessary for us to go into that question. (5) THE only point that we have got to decide is whether the assessee company is entitled to the exemption asked for by it. S. 5(2) to the extent relevant for our present purpose reads : "5(2). Hence it is not necessary for us to go into that question. (5) THE only point that we have got to decide is whether the assessee company is entitled to the exemption asked for by it. S. 5(2) to the extent relevant for our present purpose reads : "5(2). .In this Act the expression taxable turnover means in the case of a dealer who is liable to pay tax under S. 4, that part of his gross turnover during any period which remains after deducting therefrom- (A) his turnover during that period on (I) * * * (ii) sales to a registered dealer of goods of the class or classes specified in the certificate of registration of such dealer, as being intended for resale by him, or for use by him in the manufacture of goods for sale or for use by him in the execution of any contract." (6) WE have now to find out what exactly is the meaning of the expression "for use by him in the manufacture of goods for sale". Identical words are used in S. 8(b) of the central Sales Tax Act, 1956. This court was called upon to find out the scope of that expression in M/s. J. K. Cotton Spinning & Weaving Mills Co. Ltd. v. Sales Tax Officer, Kanpur and Another. Dealing with that expression this court observed : ""THE expression "in the manufacture of goods" would normally encompass the entire process carried on by the dealer of converting raw materials into finished goods. Where any particular process is so integrally connected with the ultimate production of goods that but for that process, manufacture or processing of goods would be commercially inexpedient, goods required in that process would, in our judgment, fall within the expression "in the manufacture of goods." In the present case the assessee company had sold the goods in question. to certain manufactures who were manufacturing iron steel materials. It is also clear from question No. (i) that those gloves were to be used by workmen who were engaged in hot jobs or in handling corrosive substances in the course of manufacture. That being so it cannot be denied that those gloves had to be used in the course of manufacture. (7) MR. It is also clear from question No. (i) that those gloves were to be used by workmen who were engaged in hot jobs or in handling corrosive substances in the course of manufacture. That being so it cannot be denied that those gloves had to be used in the course of manufacture. (7) MR. B. Sen, learned counsel for the Board of Revenue contended that S. 5 (2) (a) (ii) takes in only such goods which are actually used in the manufacture and not those goods which are used in the course of manufacture. It is not necessary for us to examine that contention in view of the decision of this court to which we have already made reference. We are bound by the ratio of that decision. (8) FOR the reasons already mentioned we hold that High court decision is correct. (9) IN the result this appeal fails and the same is dismissed with costs.