JUDGMENT

V. RAMASWAMI, J.:- Leave granted.

2. The first appellant - Tata Engineering and Locomotive Company Limited (hereinafter called the Company) is a company registered under the Indian Companies Act, 1913 and the second the appellant is one of its Directors. The Company is carrying on business of manufacture and sale of motor vehicles and spare parts of motor vehicles and Excavators. Their manufacturing units are at Pune and Jamshedpur outside the Thane Municipal Corporation Limits. They have a bonded warehouse within the municipal limits in which they bring and stock motor vehicles parts and excavators parts from their awn factories at Pune and Jamshedpur. They also bring in parts manufactured by their ancillaries within India and also parts imported from abroad. These products of parts are brought in bulk and thereafter taken or sent out from the Municipal limits in smaller packings depending on the requirements of the customers in various parts of the country. It is stated that the parts imported or purchased from others and brought in are relatively very small in quantity and the major portion of the activity related to their own factory produced parts.

2A. On and from 1st Oc