K.S. Radhakrishnan, J.

These revision petitions arise out of the common order passed by the Kerala Agricultural Income Tax and Sales Tax Appellate Tribunal, Addl. Bench, Kottayam in TA.261, 520 and 625 of 2003. Common issues arise for consideration in all these cases. Hence we are disposing of these cases by a common judgment. For convenient sake we may refer to the facts in STR.291 of 2005.

2. Petitioner is a private limited company engaged in the manufacture of combustible paper cartridge cases for use of the defence force. On 15-4-1999 the petitioner company entered into an agreement with another company by name Mas Combustible Pack Ltd. (MCP), Cherthala with its factory at Hyderabad for providing technology for production of combustible cartridge cases (CCC) and to help continuously by undertaking the repairs and maintenance required for machinery of the said company. Petitioner company has also agreed to depute suitable personnel to MCK factory at Hyderabad for supervising uninterrupted production of CCC. Petitioner company is entitled for 5% of the sales turnover of CCC towards remuneration for the services rendered. An agreement to that effect was executed on 15-4-