JAGADISAN, J.

The petitioners, Vishweshwardass Gokuldass are dealers in metals and mineral ores at Madras. They returned the gross turnover of the business for the year 1955-56 in the sum of Rs. 4, 12, 106-13-8. They claimed the sum of Rs. 44, 855-9-9, the labour charges paid by them for converting aluminium scraps into circles, as expenses deductible from the gross turnover. The Deputy Commercial Tax Officer, Peddunaickenpet, treated the supply of aluminium circles wrought out of the aluminium scraps as sales and estimated the turnover value of such sales at Rs. 1, 35, 355-13-0. As against this sales turnover he allowed the labour charges of Rs. 44, 855-9-9 and arrived at the net turnover. The assessees preferred an appeal before the Special Commercial Tax Officer, Madras City, and one of the objections raised by them before the appellate authority was that the supply of aluminium circles as against the aluminum scrap received from the constituents, who were supplied, with the circles, was not a sale under the Madras General Sales Tax Act, and that there could be no assessment in respect of it. This contention was however negatived by the appellate authority. There was