BALAKRISHNA AYYAR, J.

The question for determination in all these three writ petitions are the same, and, we shall therefore deal with them together.

The relevant facts are these. The Rayalseema Constructions, who is the petitioner in W.P. Nos. 91 and 142 of 1957, is a firm of construction engineers. For the year 1951-52 the firm was assessed under the Madras General Sales Tax Act, 1939, on a gross turnover of Rs. 2, 23, 174-10-0 as on "works contracts". The order of assessment was made on 25th March, 1953, and, it was then determined that a sum of Rs. 2, 440-15-7 was payable by the firm. Deducting the payments made by the firm a balance of Rs. 775-15-7 remains due in respect of this assessment. For the year 1952-53, the gross turnover of the firm was computed to be Rs. 2, 54, 666-13-9 and the assessment was made in a sum of Rs. 2, 785-6-9. Deducting the various payments made by the firm a sum of Rs. 1, 725-6-9 remains due in respect of this assessment.

The Department demanded payment of these sums amounting to Rs. 2, 501-6-4. By that time this Court had held in Gannon Dunkerley & Co. (Madras) Ltd. v. State of Madras that "works contracts" did not involve any element of sa