KANAKARAJ, J.

These four revision petition by the Revenue are against the common order of the Tamil Nadu Sales Tax Appellate Tribunal dated 3rd August, 1982, in four appeals preferred by the respondent-assessees in respect of four assessment years 1973-74, 1974-75, 1975-76 and 1976-77. The facts are as follow :

The assessees are manufacturers and dealers in cycle and cycle parts. They purchased dynamo lamps from one T. I. Millers Ltd., Madras by issuing form XVII declaration under section3(3) of the Tamil Nadu General Sales Tax Act, 1959 (hereinafter called "the Act"). Consequently their sellers charged concessional rate of tax at 3 per cent on their sales and paid tax at that rate. The turnover for the four years were as follows :

1973-74 .... Rs. 2, 17, 874.56

1974-75 .... Rs. 1, 89, 193.08

1975-76 .... Rs. 95, 705.17

1976-77 .... Rs. 1, 30, 665.00

The assessees sold the dynamo lamps with the cycles. The Assistant Commissioner found that the assessees had not used the dynamo lamps as component parts of the cycles but only as accessories to the cycles. Consequently he found that the assessees ought not to have given the form XVII declaration enabling payment of concessional r