M. B. SHARMA, J. - In the above numbered writ petitions there is challenge to rule 46(2) of the Rajasthan Sales Tax Rules, 1955 (for short, "the Rules'). In some there is additional challenge to rule 29(2) of the Rules, whereas in few others there is also challenge to section 5(3), section 23 of the Rajasthan Sales Tax Act, 1954 (for short, "the Act) and the Notifications dated May 28, 1987, March 8, 1988 and June 28, 1989. Therefore, all the above numbered writ petitions are being disposed of by a common order. During the course of arguments none of the learned counsel for the petitioners in any of the writ petitions raised any challenge to section 23(2) and the above referred to three notifications and therefore we will confine to the remaining challenge as aforesaid. In the case of State of Madras v. Gannon Dunkerley & Co. (Madras) Ltd. [1958] 9 STC 353 (SC); AIR 1958 SC 560, the Supreme Court held that the expression "sale of goods" as used in entry 54 of List II (State List) of the Seventh Schedule to the Constitution of India or entry 48 of List II of the Seventh Schedule to the Government of India Act, 1935, has the same meaning as in the Sale of Goods Act, 1930. It