( 1 ) THIS is a Reference under sec. 34 (1) of the Bombay Sales Tax Act 1953 The business of Messrs. Abdul Rehman Alladin the respondents herein consisted of purchasing old motor-cars and dismantling the same and deriving spare parts therefrom and parts which could not be used as spare parts and of selling the spare parts without moulding repairing or changing them in any way. The respondents also sold old motor-cars and scrap. The respondents applied for registration on 11th July 1955 as by that date according to them their turnover had exceeded Rs. 25 0 The Sales Tax Officer by his order dated 11th July 1955 took the view that the respondents were liable as dealers who processed goods with effect from 1st April 1954 when their turnover was taken to have exceeded Rs. 10 0 The matter went in appeal before the Assistant Collector of Sales Tax who set aside the assessment by his order dated 9th JUly 1956. Thereafter the Additional Collector of Sales Tax in exercise of his powers of revision by his order dated 19th May 1958 held that the respondents were dealers who processed goods and restored the assessment order passed by the Sales Tax Officer. The matter was carried