(1) This is an application for quashing the order of assessment passed by the Assessing Authority under the Jammu & Kashmir General Sales Tax Act, 1962 (hereinafter to be referred to as the Act) as upheld by the Sales Tax Commr. which is the final authority under the Act. The application arises in the following circumstances.

(2) The petitioners are a public limited company incorporated under the Indian Companies Act with their registered office at Bombay. The petitioners are a firm of Engineers and Contractors and on receiving tender notices for lumpsum contracts for construction of brigdes in the State, the State accepted the petitioners tender and a Contract was entered into between the petitioners and the State through the Grovernor for execution of the contract. The petitioners submitted that the contract was an indivisible works contract on a lumsum basis. The contract extended to the construction of a bridge over Chenab at Bardari near Reasi, two bridges on Reasi-Rajouri road and a road bridge on Suina Nallah. The date of the contract is 29-7-65 and the date of the completion of the contract var