The judgment of the Court was delivered by

M. N. RAO, J. - In this batch of six cases, the common question for consideration concern the application of section 5-E of the Andhra Pradesh General Sales Tax Act, 1957 (hereinafter referred to as "the Act") to the hire transaction of M/s. I.T.C. Classic Finance and Services Ltd., Secunderabad - the appellant in Spl. Appeal No. 1 of 1995 and the petitioner in the other five write petitions. We are, therefore, inclined to dispose of all the six cases by this common judgment.

M/s. Classic Finance and Services Ltd. (hereinafter referred to as "the assessee") is a limited company incorporated under the Companies Act, 1956, with its registered office at 5/2, Russel Street and branch office at No. 31, Sarojini Devi Road, Secunderabad. The assessee is registered dealer under the Andhra Pradesh General Sales Tax Act and the Central Sales Tax Act. It ia a finance company. It hires machinery, plant and equipment to different parties for rent. It purchases goods according to the specifications of the customers and instructs the supplier/manufacturer to consign the goods directly to the customer, who takes the same on hire.

During the asses