RAJAGOPALAN, J.

Though the assessee was taxed on the same basis for three years, this petition is only with reference to the assessment of one year, 1950-51. The assessee was described as a job printer, and during the assessment year 1950-51 has was assessed to a total turnover of Rs. 19, 921-7-6. This was made up of three items :

(1) Receipt for Civil Court work ... Rs. 3, 664 4 3

(2) Printing, perforating, numbering and binding charges ... 10, 194 3 6

(3) Paper used by the Press ... 5, 362 15 9

The contention of the assessee was that it was only the third item that constituted sales liable to sales tax; but in this case, as that turnover was less than the taxable turnover of Rs. 10, 000, that item was exempted from sales tax. With reference to items 1 and 2, the contention of the assessee was that they did not amount to works contracts even as defined by the Sales Tax Act, but that they represent only the labour charges. Quite obvious that contention would apply to the second item, i.e., charges for printing etc., Rs. 10, 194-3-6. The contention of the assessee, however, was repelled by the Department, and was also rejected by the Appellate Tribunal.

The Tribunal itself fou