JUDGMENT

R.C. Lahoti, J.-The question arising for decision in these appeals is whether the transactions involved in manufacture and supply of ships by the appellant to its customers are a sale as defined in clause (n) of Section 2 of the Andhra Pradesh General Sales Tax Act, 1957 (hereinafter the Act , for short) as held by the High Court or a works contract as defined in clause (t) of Section 2 of the Act and hence not exigible to sales-tax as contended by the assessee-appellant.

2. M/s. Hindustan Shipyard Limited, the appellant before us, is a public sector undertaking. It is engaged in the activity of building ships for different ship owners under the orders placed by them and as evidenced by the contracts entered into between them.

3. The facts in brief. Between the assessment years 1974-75 and 1983-84 (both years inclusive) there were 18 ships involved and formed subject matter of different assessments. The Assessing Authority and the Commissioner (Appeals) held all the transactions in question as transactions of sale liable to payment of sales-tax by the appellant. Several tax appeals preferred by the appellant were disposed of by the Sales Tax, Appellate Tribunal, Andhra P