Ramaprasada Rao, J.-

The petit: oners, the General Electric Company of India Private Ltd., are dealers in all kinds of electrical goods, and they undertake also works contracts on behalf of others. During the year 1957-58 an overall assessment of all the transactions of the petitioners was made by the Additional Commercial Tax Officer IV, South Madras. An appeal was preferred by the petitioners against the order of the Assessing officer, in which inter alia the petitioners disputed their liability on a turnover of Rs. 7,00,958-20 alleging that they constituted receipts on account of alleged works contracts. Five contracts were in all involved. Being unsuccessful before the appellate authority, the petitioners filed an appeal before the Sales Tax Appellate Tribunal, Madras, regarding the receipts relating to the works contracts executed by them for the benefit of the Life Insurance Corporation of India and the Superintending Engineer, Basin Bridge Power Station, and other items of their dealings as well. Their contention did not find favour with the Tribunal, with the result the petitioners have now come up to this Court and contended in the main that a sum of Rs. 2,44,121-62 receive

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