ISMAIL, J.

All these petitions relate to the same matter in respect of the same respondent for different years. The respondent is an institution carrying on a co-operative research in textile industry and it is supported by the Council of Scientific and Industrial Research of the Government of India. This organisation comes under the overall administrative control of the Government of India, and it is financed in equal proposition by the Government of India and the member-mills of the industry. The respondent purchased cotton for its day-to-day research activities. There is no controversy that the purchase of cotton was only for the object of consuming it is the process of the research it carries on. The yarn which is produced in the process is broken, unwound and entangled in the course of testing process and is disposed of as such. For improving productivity and quality, the respondent undertook testing and analysis of the sample and encouraged the member-mills. The respondent also assisted such member-mills in the design and lay-out of the laboratory as well as in the selection of appropriate instruments. The question for consideration was, whether the purchase of cot