The judgment of the Court was delivered by

Y. V. ANJANEYULU, J. - These two tax revision cases were filed by the State and the respondent is the same in both the cases. The two cases relate to the sales tax assessment years 1974-75 and 1975-76. A common question arises for consideration in both the cases and it will be convenient to dispose of those together.

2. The assessee carries on business in wheat products. In accordance with the licence issued by the Director of Civil Supplies, the assessee was under an obligation to sell atta, maida and other wheat products to the person nominated by the Director. During the financial year 1974-75, the assessee supplied wheat products of the value of Rs. 45,11,740 to the persons nominated by the Director of Civil Supplies; for the assessment years 1975-76 the assessee likewise supplied wheat products of the value of Rs. 79,61,310 to the nominees of the Director. In connection with the sales tax assessments for these two years the assessee claimed that the supplies of wheat products made to the persons nominated by the Director of Civil Supplies cannot be regarded as "sales" within the meaning of section 2(n) of the A.P. General Sal