JUDGMENT

The judgment of the Court was delivered by

SHAH, J.-The respondents carry on business as "engineers and contractors" and as dealers in iron and steel goods and refrigerating and cooling units etc. For the assessment year 1957-58 the assessing authority, Madras, included in the taxable turnover of the respondents for assessment TO Central sales tax the following two items received by the respondents Which they contended were not liable to be included :

(i) Rs. 3,26,075.20 under a contract for the fabrication, supply and erection of steel structures with a co-operative society which was setting up a sugar factory in the State of Mysore; and

(ii) Rs. 43,349.05 for the fabrication and installation of "bottle coolers" under orders from customers at different places.

The assessing authority rejected the claim of the respondents. In the view of the assessing authority under the terms of the contract with the co-operative society the respondents manufactured certain articles according to specifications and despatched them to Mysore State and there-after the articles were installed by the employees of the respondents at the site of the factory of the society, arid on that account the tr