Paripoornan, J.

The Revenue is the revision-petitioner herein. The matter arises in connection with an amendment effected in the Registration Certificate of the respondent/ assessee, a registered dealer under the Central Sales tax Act. The assessee is the Proprietrix of Laxmi wood Peelers and Shama Retreads. She sought for inclusion of certain items of equipments used in tyre retreading business in the Registration Certificate under the C.S.T. Act. The certificate was amended on 26-9-1987, as applied for by the

respondent/ assessee. Thereafter, the assessing authority felt that 'Tyre Retreading' does not amount to 'sale' as defined in S.2(g)of the C.S.T Act. It was held that'Tyre Retreading' was only works contract. On that basis, it was held that S.8(1) and 8(3) of the C.S.T. Act are inapplicable to the retreading activities of the assessee/ respondent. As soon as this aspect was found out, the amendment effected to the Registration Certificate under the C.S. T. Act including items required for tyre retreading business was cancelled. The assessee/respondent took up the matter in appeal before the appellate Assistant Commissioner. The appeal was dismissed. In second appea