K. J. SHETTY, C. J. ( 1 ) THIS is the second time the matter is coming before the Full Bench. ( 2 ) THE primary question that arises for consideration is whether woollen cardigans and pullovers are to be treated as articles of hosiery or as woollen goods. ( 3 ) THE turnover relating to articles of hosiery is taxable at the rate of 3 per cent as per notification No. 3613 dated July 1, 1969; whereas that of woollen goods is taxable at 6 per cent under Notification No. 1365/x-9-56 dated April 1, 1969. ( 4 ) THE answer to the question, in our view, presents no problem and it may be sufficient if we may set out the events leading to the petition before us. ( 5 ) THE British India Corporation Ltd. (BIC), was an assessee under the U. P. Sales Tax Act, 1948. In the assessment year 1970-71, it had a turnover of over a crore of rupees relating to the sale of woollen cardigans and pullovers. All the authorities under the Act brought the turnover to tax at per cent treating the same as sale of woollen goods and not as a turnover relating to articles of hosiery. The BIC preferred a Revision Petition No. Ill of 1980 in this Court under Section 11 (1)of the U. P. Sales Tax Act. The case had a circuitous way before several Judges in this Court. The learned single Judge, before whom the revision first came up for hearing, found that there has been a conflict of opinion expressed by this Court in various decisions and he referred the matter to a Division Bench (R. M. Sahai and V. K. Mehrotra, JJ. ). The matter, argued before the Division bench, only led to a further conflict as between the two learned Judges. Thereupon; the matter inevitably came before a third Judge (H. N. Seth, J. , as he then was ). H. N. Seth, J. , while agreeing with the view taken by R. M. Sahai, J. , that the cardigans and pullovers are items of hosiery, however, felt that the law laid down by this Court in another case, i. e. , Laxmi Stores case 1982 uptc 425, taking a contrary view, requires reconsideration. So, the learned Judge thought it proper that the matter ought to be decided by a larger Bench. So, the learned Judge thought it proper that the matter ought to be decided by a larger Bench. The Chief Justice, accordingly, constituted a Full Bench consisting of Satish Chandra, C. J. , K. N. Singh, J. (as he then was) and b. N. Sapru, J. The learned Judges, after considering the entire matter, were of the opinion that it would not be proper to decide the question on the basis of decisions alone and it would be more appropriate to consider the question as to how the said articles are understood in common parlance. So stating, the Full Bench formulated a question and transmitted the same to the tribunal with a direction to record a finding after affording opportunities to parties to adduce evidence. The question referred to reads : whether in commercial circle woollen cardigans and pullovers are treated as articles of hosiery or as woollen goods ? ( 6 ) PURSUANT thereto, the matter was taken up by the Sales Tax Tribunal and it has, by an order dated March 10, 1986, transmitted its finding to this Court. ( 7 ) THE Tribunal, on an appraisal of evidence adduced by both the parties, held that woollen cardigans and pullovers are treated in commercial circles as articles of hosiery and not as woollen goods. The matter has thus come up before us for final disposal. ( 8 ) THE question formulated, in our opinion, does not require any further arguments. The Tribunal has reached the conclusion, on the facts and circumstances before it, that the articles like woollen pullovers and cardigans are considered as hosiery in common parlance and commercial circle. That is a finding of fact binding on this Court in the revision under Section 11 of the U. P. Sales tax Act. Under the said section, revision lies only on a question of law, as it is evident from sub-sections (4) and (8) thereof. ( 9 ) WE, therefore, accept the finding recorded by the Tribunal in regard to the articles in question and hold that the turnover relating to woollen pullovers and cardigans was liable to be taxed as hosiery goods. ( 10 ) IN the circumstances of the case, we make disposed of (sic ). --- *