Ramachandra Aiyar, J.-

These tax revision cases are filed under section 12-B (1) and rule 13 (c) (1-A.) of the Madras General Sales Tax Act. The assessee is the petitioner in all these cases and they relate to assessments in respect of years, 1949-50 to 1952-53. Sundaram Motors (Private) Ltd., the assessee, is a private limited company incorporated under the Indian Companies Act, and it carries on business in selling and distributing motor vehicles. It also deals in motor parts and accessories and maintains a workshop where reconditioning or repairs of motor vehicles are undertaken. The turnover in the business of the company would, therefore, relate to the sales department, where the goods are sold, and also to the works department where the vehicles are repaired or reconditioned. In the latter case, the turnover represent not merely the labour charges as such but the cost of spare parts or would material supplied or used in effecting the repairs. There is no controversy in regard to the turnover in the sales department and these revision cases are concerned mainly with the transactions in the workshop department of the company.

Although the turnover for the various assessment year

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