These revision petitions under section 11 of the U. P. Sales Tax Act are directed against a common order dated July 21, 1995 passed by the Sales Tax Tribunal, Kanpur, whereby it dismissed the dealers second appeal against the levy of penalty under section 8-D (6) in the sums of Rs. 89,000, Rs. 1,00,000 and Rs. 1,72,690 respectively for the assessment years 1987-88, 1988-89 and 1989-90.

I have heard the learned counsel for the revisionist Sri Rakesh Kumar Agarwal and Sri R. D. Gupta, learned Standing Counsel.

By section 3-F inserted with effect from September 13, 1985 transfer of property in goods, whether as goods or in some other form involved in the execution of a works contract became taxable under the Act. Section 8-D, that was enacted by U. P. Act No. 17 of 1987 with effect from April 27, 1987, made a provision for deduction of tax at source and obliged every person for making to any dealer for discharge of any liability on account of valuable consideration for the transfer of property in goods, whether as goods or in some other form in pursuance of a contract not being a contract of such class or value as may be notified by the State Government to deduct an