SEETHARAM REDDY, J.

( 1 ) IN this batch of revisions, preferred against the order made by the Sales Tax Appellate Tribunal, the question that arises for determination is whether the sales effected during the assessment years 1969-70 to 1980-81 by the Andhra Pradesh State Road Transport Corporation ("apsrtc" for short) in respect of scrapped vehicles, old tyres, tubes, tender forms and other unserviceable material, would be exigible to sales tax. The Appellate Tribunal held that it is not possible to hold that the corporation is carrying on any business or it is a dealer. Therefore, the sale of discarded and unserviceable material by it amounts to no business.

( 2 ) THE contention of the Revenue is that the activity of the corporation is nothing but commercial in nature and, therefore, it must be held that it is carrying on business and consequently the scrap material which the corporation is selling away must be held to be incidental to its main activity and, therefore, the sale of such scrap material must be subjected to sales tax. It is further contended that though the activity of the corporation is commercial in nature which might not attract sales tax but any other activity li

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