The judgment of the court was delivered by

MADHAVA REDDY, J. - The Andhra Pradesh State Road Transport Corporation was provisionally assessed to sales tax on a taxable turnover of Rs. 4,85,321 in respect of the sale of scrapped vehicles and other scrap effected during the period 1st April, 1966, to 30th September, 1966. The Corporation contends that these transactions could not be deemed to be business of the Corporation so as to make it liable to be assessed to tax on the value realised by such sale.

The Andhra Pradesh State Road Transport Corporation is constituted under the Road Transport Corporation Act, 1950. The object of this Corporation is to provide or secure or promote the provision of an efficient, adequate, economical and properly co-ordinated system of road transport service in the State. It is not a trading Corporation. Ever since it was constituted in 1958 it has been operating bus services on various routes in the State. In the course of its activity, scrapped vehicles, old tyres, old containers and other unserviceable material were left with the Corporation which it has been disposing of periodically by public auction or by inviting tenders. The proceeds o