( 1 ) THESE revision petitions are filed against the common order passed by the Karnataka Appellate tribunal in the appeals filed by the assessee and the cross-appeal filed by the Revenue for the assessment years 1990-91 and 1991-92 under Section 12a of the Karnataka Sales Tax Act ("the kst Act", for short) and for the assessment years 1994-95, 1995-96 and 1996-97 under Section 12 (3) of the Act and also the levy of penalty for the years 1990-91 and 1991-92 under Section 12-A (1-A) of the Act.

( 2 ) BRIEFLY stated for the purposes of these revision petitions, the facts are : the respondent is a public limited company. It is engaged in the business of manufacture, supply and installation of lifts and elevators. The respondent-company has branches all over the country. It has its manufacturing unit for lifts and elevators at Ghaziabad, U. P. The respondent-company at Bangalore undertakes designing, manufacture, erection and commissioning of lifts and elevators according to the requirements of individual customer. The registered office at Bangalore procures orders from customers in Karnataka towards supply, erection and commissioning of lifts and elevators, but the m