SYED SHAH MOHAMMED QUADRI, J.

( 1 ) M/s. Hindustan Shipyard Limited, Visakhapatnam, is the petitioner in these tax revision cases. As facts giving rise to these cases and contentions urged are common, we have heard them together and are disposing of by a common judgment.

( 2 ) THE petitioner, under different contracts, delivers ships to various persons. It is the nature of the transaction which is the subject-matter of these contracts that is debated before us. The contention of the petitioner is that the nature of transaction covered by the contracts is one of the agreement to build the ship, in other words a works contract. Whereas the contention of the sale tax authorities is that the transaction was nothing but sale of goods. The assessing authorities levied the tax on those transaction treating them as agreements of sale of ships. The appellate authority - Deputy Commissioner dismissed the appeals. Not satisfied with the orders of the appellate authority - Deputy Commissioner, the petitioner filed appeals before the Sales Tax Appellate Tribunal. The Tribunal disposed of the appeals filed by the petitioner in respect of different assessment years following its own decision in T

Click Here to Read the rest of this document