Thomas, J.

In these connected cases, the validity of certain provisions of the Kerala General Sales Tax Act, 1963 (for short'the Act') and the particular Rule framed under the Act has been challenged by different persons who have undertaken contract work in different areas. As per the impugned provisions sales tax has been levied on the sale of goods involved in what is called "works contract", S.2(viii), S.2(xxi) read with Explanation 3(A), S.2(xxvii) read with Explanation 1(A), S.2(xxvi), S.2(xxv) and S.5(1)(iii) of the Act and Rule 8(4) of the Kerala General Sales Tax Rules (for short'the rules') are the provisions principally assailed herein. When these cases came up before a Division Bench on reference, it was felt that the issues involved are of far-reaching importance and of substantial revenue and hence, the Division Bench referred these batch of cases to a Full Bench. It was thus that the cases have reached us.

2., The impugned provisions as such were brought into the Act by means of

y amendments carried out from 1-4-1984 to 1-7-1987. We make it clear mat the challenge is confined to these provisions which remained on the statute book as on 1-7-1987. We state this