Official Gazette notifications are part of law, not additional evidence, so appellate consideration of appended forms was permitted.

A notification published in the Official Gazette and the forms appended to it were treated as part of the law, not as factual material or additional evidence. Because a statutory instrument with the force of law does not fall within the meaning of oral or documentary additional evidence, the restriction in section 39-A of the Madhya Pradesh General Sales Tax Act, 1958 did not apply. The appellate authority and Tribunal were therefore bound to consider the notification and its appended forms, and the assessee succeeded on that point.

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Issues: Whether the forms appended to Notification No. 966-655-V-ST dated March 28, 1969, could be produced at a later stage notwithstanding the bar against additional evidence under section 39-A of the Madhya Pradesh General Sales Tax Act, 1958.

Analysis: A notification published in the Official Gazette is not factual evidence but part of the law operating in the relevant field. A statutory instrument having the force of law cannot be equated with oral or documentary additional evidence within the meaning of section 39-A. The notification, and the forms appended to it, were therefore required to be taken into account by the appellate authority and the Tribunal. The statutory bar against additional evidence was held inapplicable to such a legal instrument.

Conclusion: The question was answered in the affirmative. The Tribunal was justified in taking notice of the notification and its appended forms, and the assessee succeeded.

Ratio Decidendi: A notification published in the Official Gazette and having the force of law is not additional evidence, and therefore its production or reliance upon is not barred by provisions restricting additional evidence at appellate or revisional stages.

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