( 1 ) THE appellant is a public limited company engaged in the manufacture and supply of Automated Teller Machines (ATM's for short ). In view of the configuration and for the purpose for which is put to use, the appellant company is of the view that the sale of ATM's is eligible to single point levy of tax under Sec 5 (3) (a) of the Karnataka Sales Tax Act, 1957 (hereinafter for the sake of brevity referred to as 'act, 1957 ). However, in order to have the views of the department in this regard, in particular, the Advance Ruling Authority constituted by the Commissioner of Commercial Taxes in exercise of his powers under Section 4 of the Act, the appellant company had filed an application before the Advance Ruling Authority in Form 54 as provided under Rule 27-E (1) of the Karnataka Sales Tax Rules, 1957 ('rules' for short), seeking clarification on the rate of tax applicable under the Act on sale of Automated Teller Machines.

( 2 ) IN response to the notice of the hearing issued by the Advance Ruling Authority, Sri Mohan Mudkavi learned Chartered Accountant along with the Vice-President of the Company had appeared before the Authority and represented the facts and als