S. SANKARASUBBAN, J. –

These T.R.Cs. are filed against the common order passed by the Sales Tax Appellate Tribunal, Additional Bench, Ernakulam, in 12 appeals. The assessment years are 1986-87 to 1991-92 and from 1992-93 to 1995-96. Assessee is M/s. Siemens Limited. The facts necessary for the disposal of this case are as follows :

Petitioner is an assessee on the rolls of the Assistant Commissioner (Assessment), Sales Tax, Special Circle II, Ernakulam. While completing the assessment in respect of the assessee for the relevant years, the assessing authority disallowed the following claims of exemption made under section 6(2) of the Central Sales Tax Act, 1956 (hereinafter referred to as "the CST Act") :

1986-87 ... Rs. 50,17,537.00 1987-88 ... Rs. 31,84,914.00 1988-89 ... Rs. 46,00,265.00 1989-90 ... Rs. 4,53,114.00 1990-91 ... Rs. 27,99,864.00 1991-92 ... Rs. 29,63,052.00 1993-94 ... Rs. 7,63,225.00 1994-95 ... Rs. 1,42,15,090.00 1995-96 ... Rs. 62,42,389.00

The assessee claime