RAMAMURTI, J.

The petitioner in the tax revision case is Richardson and Cruddas Ltd., a limited liability company, carrying on business in structural engineering work, and as contractors at the First Line Bench, Madras. It is admitted that in the course of its business the petitioner-company fabricates and erects heavy steel structures on behalf of its customers in connection with the construction of sugar factories, etc. It is also admitted that in the course of its business the petitioner-company receives order for the manufacture, fabrication and installation of cooling apparatus, like air coolers, bottle coolers, which are specially manufactured according to the special requirements and specifications of the customers and installed in the latter's premises by the use of skill and labour bestowed by experienced mechanics and specialists engineers of the petitioner-company.

In this revision petition, which relates to the assessment year 1957-58, the dispute relates to three items. The first item is with regard to the turnover of a sum of Rs. 3, 26, 075.20 nP. received from its customers, Pandavapura Sahakara Sakhare Karkhane Ltd. (hereinafter called the sugar factory),