VEERASWAMI, J.

These petitions raise a common point and have, therefore, been heard together. The question is whether what is described as lot cooly charges paid on a percentage basis by the customers to the different assessees form part of the turnover chargeable to sales tax. These charges were not included as being taxable in the initial assessments, but they were reopened and the charges, as forming part of the turnover, were subjected to tax. The typical reasoning of the revenue for doing so is that the amount was charged and paid at the time of sale "along with the price of the goods" and so, it formed part of the turnover within the meaning of the definition of "turnover", An additional reason in support of that view was that lot cooly could not also fall within the scope of any of the items for which deduction was provided by rule 6 of the Madras General Sales Tax Rules, 1959. Broadly, therefore, the view maintained by the revenue is that charges, which may well be described as pre-sale charges, should be treated as part of the consideration for a sale and the lot charges partook of that character.

The charges appear to be paid by the customers, no doubt, at the t