Ramesh Ranganathan, J.

1. These appeals are preferred, under Section 23(1) of the APGST Act against the order passed by the Commissioner of Commercial Taxes dated 23.07.2003, setting aside the orders of the Appellate Deputy Commissioner, Guntur and Vijayawada, and restoring the orders of the assessing authority.

2. It would suffice, for the purpose of adjudicating this batch of special appeals, if the facts in Special Appeal No. 49 of 2003 are noted. The appellants herein, manufacturers of cine-wall posters, were finally assessed to tax, both under the APGST Act and the CST Act, from the assessment year 1985-1986 upto the year 1990-91, on the turnover relating to cine wall posters treating them as sales exigible to tax under the APGST and the CST Acts. Aggrieved thereby, the appellants carried the matter in appeal, before the Appellate Deputy Commissioner, contending that their business related purely to skill and labour, and not to sale of goods or material; the entire process of litho-printing involved high skill, at several stages, before the cinema wall posters came into existence; the following steps were involved in the process of manufacture of cine wall posters (1) pr