BALASUBRAHMANYAN, J.

In this tax revision arising under the Tamil Nadu General Sales Tax Act, 1959, the question is whether the assessee sold printing paper and then got it back from the customers for the purpose of carrying out printing work on such paper. The Tribunal has recorded a finding that the contracts between the assessee and his customers are indivisible contracts under which then assessee undertook to deliver printed material in accordance with the customers' instructions. The Tribunal therefore considered the receipts in the assessee's business as representing turnover in sales of goods taxable under the Act. For the same reason, they rejected the contention of the assessee that the turnover only represents receipts from works contracts.

The learned counsel for the assessee submitted that the order forms, on the basis of which the transactions took place as between the customers and the assessee clearly distinguish between the two transactions, one, the supply of paper by the assessee to the customers at a price, and the other, the cost of the printing, the two being set out in separate columns in the order forms. The learned counsel drew our attention to som