(Per H. L. Dattu, J.)

These two Appeals are filed against the order passed by the Additional Commissioner of Commercial Taxes, Zone-I, Bangalore, in 1989-90 and 1990-1991, dated 15.7.1996. By the impugned order, the Revisional Authority has set aside the orders passed by the Joint Commissioner of Commercial Taxes (Appeals) in Appeal Nos. 364 and 365 of 1994-95, dated 25.2.1995 and further has modified the orders passed by the Assessing Authority under Section 12A of the Karnataka Sales Tax Act, 1957, dated 12.1.1995 and 21.12.1994 for the Assessment Orders 1990-91 and 1989-1990 respectively to the extent of computing the turnover after allowing 10% of the total Contract Receipts as deductions under rule 6 of the Karnataka Sales Tax Rules, 1957.

The facts in brief are :

The Assessee is a dealer registered both under the provisions of Karnataka Sales Tax Act, 1957 ('KST Act' for short) and the Central Sales Tax Act, 1956 ('CST Act' for short) and is engaged in the business of supply and development of Computer Software. For the Assessment Years 1989-1990 and 1990-1991, the Assessee had filed its Annual Returns and in that had claimed exemption on inter-State sales, export tu