A.RAMANUJULU NAIDU, B.J.DIVAN
Board of Trustees of the Visakhapatnam Port Trust, represented by the Secretary – Appellant
Versus
Commercial Tax Officer, Visakhapatnam – Respondent
( 1 ) THE same question arises for determination in each of these matters. The petitioner in each of these writ petitions is the Board of Trustees of the Visakhapatnam Port Trust. The main question which arises for determination in these cases is whether the board of Trustees can be said to be a dealer within the meaning of section 2 (c) of the Andhra Pradesh General Sales tax Act, 1957, (hereinafter referred to as the Act ). The Sales Tax Authorities have held that the Board of trustees is a dealer and, on that footing, proceeded to assess the Board of Trustees to sales tax for the different assessment years 1969-70 to 1974-75. The Sales-Tax Authorities have assessed and proposed to assess the Board of Trustees to sales-tax in respect of several commdities in which, according to those authorities, the board of Trustees have been dealing from time to time. The commodities on which the salestax has been assessed or proposed to be assessed are as follows: (a) supply of water to visiting vessels; (b) bunkering of visiting vessels with liquid fuels; (c) offering of tender documents for a consideration to prospective contractors; (d) supply of water and issue of stores to
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