The petitioner in these two writ petitions is the Southern Railway Employees' Workshop Canteen, Golden Rock, Tiruchirapalli, the first respondent is the Deputy Commercial Tax Officer, Tiruchirapalli Town IV, and the second respondent is the Appellate Assistant Commissioner (C.T.), Tiruchirapalli. The petitioner's contentions are briefly the following. The Southern Railway Workshop at Golden Rock employs about 6, 000 workers apart from the clerical and office staff. As required under the provisions of section 46 of the Factories Act (Central Act 63 of 1948) and the rules framed thereunder, the railway is obliged to maintain a canteen for its employees where eatables are supplied to them on a non-profit basis, in other words, on the basis that there should be no motive to make a profit. Thus, there is no commercial aspect in the sales effected at the canteen by the petitioner to these workers, and therefore the petitioner could not be deemed to be engaged in business so far as this canteen is concerned, and it could not also be treated as a dealer for the purpose of the Madras General Sales Tax Act of 1959 (Act 1 of 1959), hereinafter called the Act. Nevertheless, the fir