K. RAVICHANDRABAABU, J.

1. Both these writ petitions are filed by the very same petitioner challenging the order of the respondent dated 28.07.2017 in revising the assessment made under Central Sales Tax Act, in respect of the assessment years 2014-15 and 2015-16. The issue involved in both the writ petitions is one and the same and therefore, the facts narrated hereunder are common to both these Writ Petitions.

2. The case of the petitioner is as follows:

(a) The petitioner is a manufacturing Company of motor vehicles and also a registered dealer on the file of the respondent under the provision of Tamil Nadu Value Added Tax Act, 2006 and the Central Sales Tax Act, 1956. The petitioner sold the motor vehicles to two of its sister Companies which are marketing Companies and separate entities. The said marketing Companies namely, M/s. Renault India Private Limited and M/s. Nissan Motor Private Limited, are separate business entities and are engaged in the activities of marketing, distribution and selling the motor vehicles manufactured by the petitioner. Those two Companies, besides having stockyard in the State of Tamil Nadu, also have stockyard in Andhra Pradesh. They purchas