ISMAIL, J.

These tax revision cases arise out of the order of the Sales Tax Appellate Tribunal, Main Bench, Madras-1, dated 11th March, 11th March, 1971, in respect of two assessment years 1966-67 and 1968-69, and the controversy is very narrow. The assessee in these cases entered into contracts with the Universities and the other educational institutions in the country for printing question papers for the said educational institutions. The assessee in the demand notes prepared gave the charges for printing, blocks, packing charges, handing charges, delivery charges, postage, value of paper and value of packing materials separately in the relevant assessment years. The dispute related as to whether the taxable turnover should include the printing charges and block-making charges or not. As far as the assessment year 1966-67 is concerned, the printing charges amounted to Rs. 99, 675.00 and block-making charges amounted to Rs. 2, 923.95 totalling Rs. 1, 02, 598.95. As far as the assessment year 1968-69 is concerned, the printing charges amounted to Rs. 1, 33, 137.00 and block-making charges amounted to Rs. 5, 361.75 totalling Rs. 1, 38, 498.75. The question to be considered is whether these two amounts were includible in the assessable turnover in the respective years in question. The case of the respondent was that the contract entered into between her and the respective educational institutions was a contract of work and labour and in the performance of that contract, incidentally she had to sell paper to them and, therefore, except to the extent of the cost of paper, in respect of the other amounts received by her she was not liable to pay any sales tax. On the other hand, the case of the Government was that the contract was for the sale of printed materials by the respondent to the respective educational institutions and, therefore, the entire amount will have to be taken into account as turnover liable to tax. We may point out in this context that till the year 1963 the respondent herself was doing the printing and during that period the Tribunal has been holding that only the cost of the paper was liable to be included in the taxable turnover. With effect from 3rd November, 1963, the printing work was done by a firm of which the assessee's sons and daughters were partners, but the contract continued to be entered into between the respondent and the respective educational institutions. According to the Government, this made a difference and, therefore, the earlier order of the Tribunal cannot govern the assessment for the respective years referred to above. The Tribunal held that there was not need to change the view it had already adopted in view of the fact that the printing work was done by a firm consisting of the sons and daughters of the respondent and even after the change it is only the value of the paper that was liable to be included in the taxable turnover. It is the correctness of this conclusion of the Tribunal that is challenged in the form of the two revision cases preferred to this court under section 38 of Tamil Nadu Act No. 1 of 1959.We are clearly of the opinion that the contract entered into between the respondent and the Universities and the other educational institutions was a composite contract in the sense it was a contract for work and labour as well as contract for the sale of the paper, since there was an express agreement for the sale of the paper by the respondent to the Universities and other educational institutions in question. The learned Additional Government Pleader drew our attention to the decisions holding that the sales of printed bills or printed account books or printed books have been held to be sales attracting liability to sales tax because all of them happen to be sales of printed materials and exactly on the same pattern, the present case involves sale of printed materials, viz., printed question papers and, therefore, the entire consideration received by the responde