( 1 ) THE Judgment of the Court was delivered by the Hon ble The Chief justice. This is a revision against the order of the Andhra Sales Tax Appellate tribunal confirming that of the Commercial Tax Officer, East Godavari district. The petitioner carries on the business of baling and pressing palmyra fibre. He purchases gunny cloth and iron hoops for the purpose of using them in the baling process. For the year 1951-52, the Sales Tax authorities assessed him to sales tax on a turnover of Rs. 22,865-7-6 being the value of gunny cloth and iron hoops. It was contended before the Tribunals that the contracts entered into between the petitioner and his constituents were work contracts and that the gunny cloth and the iron hoops became an integral part of the product entrusted to him for baling and pressing. Both the Tribunals negatived the contention and held that the petitioner is a dealer and that the transactions relating to gunny cloth and iron hoops were sales within the meaning of the Act. Learned Counsel raised before us the same points, which his client unsuccessfully raised before the Tribunals. He relies strongly upon the decision of a Division Bench of the Madras High Cour

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