DR. MOTILAL B. NAIK, J.

These two special appeals arise out of the common order passed by the Commissioner of Commercial Taxes relating to assessment years 1986-87 and 1987-88. Since the grounds of appeals and issues are common in these two special appeals, they are being disposed of by this common order.

When these special appeals are taken up for consideration, the learned Special Government Pleader for Taxes appraised us about the Department filing T.R.C. No. 14 of 1999 against the order passed by the Sales Tax Appellate Tribunal and stated that the said TRC is also connected with these two Special Appeals and urged this Court to decide T.R.C. No. 14 of 1999 along with these two special appeals. Hence, we called for the records relating to T.R.C. No. 14 of 1999 and took up for consideration along with these two special appeals.

Before we set out to decide the controversy arising out of these two Special Appeals and T.R.C. No. 14 of 1999, few facts are necessary to be recorded for the purpose of convenience.

The appellant is a Public Limited Company engaged in manufacturing, fabrication, supply, erection and commissioning of various projects. The nature of work carried out