Official Gazette notification treated as law, not additional evidence, so the appellate bar did not apply.

A statutory notification published in the Official Gazette is part of the governing law, not factual evidence, and its appended forms are treated as part of the notification itself. On that basis, consideration of the notification and forms was not barred by Section 39A of the Madhya Pradesh General Sales Tax Act, 1958, which prohibits additional evidence at the appellate or revisional stage. The Tribunal was therefore justified in taking notice of them, and the referred question was answered in favour of the assessee.

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Issues: Whether a Government notification published in the Official Gazette, together with the forms appended to it, could be treated as additional evidence barred by Section 39A of the Madhya Pradesh General Sales Tax Act, 1958.

Analysis: A notification issued in the Official Gazette is not factual evidence but part of the law governing the subject matter. A statutory instrument having the force of law cannot be equated with additional evidence within the meaning of Section 39A. The forms appended to the notification were treated as part of the notification itself, and therefore their consideration was not hit by the prohibition against additional evidence at the appellate or revisional stage.

Conclusion: The bar under Section 39A did not apply. The Tribunal was justified in taking notice of the notification and the appended forms, and the question referred was answered in the affirmative in favour of the assessee.

Final Conclusion: The reference was answered by holding that a statutory notification and its appended forms may be considered as law and not as additional evidence, and the assessee succeeded on the referred question.

Ratio Decidendi: A statutory notification published in the Official Gazette is part of the law, not additional evidence, and its consideration is not prohibited by a rule barring production of additional evidence at the appellate or revisional stage.

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