Madan B. Lokur, C.J.

1. These appeals are directed against a common judgment and order dated February 1, 2006, passed by a learned single judge in W.P. (C) No. 7812 of 2002, W.P. (C) No. 5369 of 2002 and W.P. (C) No. 7896 of 2002 (S.S. Photographic Lab. Pvt. Ltd. v. State of Assam [2006] 145 STC 156 (Gauhati)). The appellants in two of the appeals are a private limited company which was earlier a partnership concern of Sanat Kumar Dey. The appellant in the third appeal is Sanat Kumar Dey. All the appellants, therefore, are really one and the same.

2. The appellants carry on the business of developing exposed photographic film rolls into negatives and then processing the negatives into positive photographs. They also process negatives received by them from customers into positive photographs. The developing and processing is done on a job-work basis and, according to the appellants, it does not involve any sale of goods or transfer of property in goods. The appellants, it appears, are not in the business of being commissioned to take photographs or processing them.

3. According to the respondents, the appellants' transactions fall within the category of "works contract'' as def