JUDGMENT :

Ritu Bahri, C.J.

All the three revisions have been filed by the revisionist for three separate years, i.e. 2007-08, 2008-09 and 2009-10.

2. The revisionist has come-up in revisions against the common order dated 13.09.2012 passed by the learned Commercial Tax Tribunal and the orders dated 6th December, 2010 passed by the Assistant Commissioner, Commercial Tax, Dehradun.

3. The revisionist is the registered owner of a bus having Registration No. UA-7Q-1941. On 10.01.2007, the revisionist entered into an agreement with the Uttarakhand Transport Corporation, by which the revisionist agreed to provide her bus on certain terms and conditions. Copy of the Agreement is filed as Annexure-1 to the revision. The respondentDepartment collected information regarding the payments made to the persons, who had provided their buses to the Uttarakhand Transport Corporation. On the basis of the information received from the said Corporation, a show-cause notice was issued to the revisionist by the Assistant Commissioner, Commercial Tax, Dehradun treating the transaction to be a deemed sale covered by “transfer of right to use”. The revisionist gave her reply, however, the Assistant Commission