Madras High Court
Sundaram Fasteners Limited vs The State Of Tamil Nadu on 20 September, 2012
Author: Chitra Venkataraman
Bench: Chitra Venkataraman, K.Ravichandrabaabu
IN THE HIGH COURT OF JUDICATURE AT MADRAS Dated : 20.09.2012 Coram The Honourable Mrs.Justice CHITRA VENKATARAMAN and The Honourable Mr.Justice K.RAVICHANDRABAABU Tax Case (Revision) Nos.2308 of 2008, 64 and 65 of 2011 --- Sundaram Fasteners Limited 98-A, 7th floor Dr.Radhakrishnan Road Mylapore, Chennai-600 004 .. Petitioner in all the above TCs -vs- The State of Tamil Nadu represented by the Assistant Commissioner (CT) Central Assessment Circle-I No.6, Greams Road, Chennai-600 006 .. Respondent in all the above TCs Tax Case (Revision) No.2308/2008 filed under Section 38 of the TNGST Act of 1959 to revise the order of the Sales Tax Appellate Tribunal (Main Bench), Chennai-600 104 dated 24.03.2000 in T.A.No.237/99 & C.O.P.No.668/99. Tax Case (Revision) No.64/2011 filed under Section 38 of the TNGST Act of 1959 to revise the order of the Sales Tax Appellate Tribunal (Main Bench), Chennai dated 03.01.2011 passed in Tribunal Appeal No.107/2004. Tax Case (Revision) No.65/2011 filed under Section 38 of the TNGST Act of 1959 to revise the order of the Sales Tax Appellate Tribunal (Main Bench), Chennai dated 03.01.2011 passed in Tribunal Appeal No.108/2004. For petitioner : Mr.N.Prasad For respondent : Mr.J.Aaditya Reddy, Govt.Advocate ********* C O M M O N O R D E R
(The Order of the Court was made by CHITRA VENKATARAMAN, J.) The assessee is on revision as against the order of the Sales Tax Appellate Tribunal (Main Bench), Chennai relating to the assessment year 1988-89 and 1999-2000 under TNGST assessment and relating to assessment year 1999-2000 under CST assessment. The following substantial question of law is raised in T.C.(R).No.2308 of 2008 :-
"1.Whether the Sales Tax Appellate Tribunal has committed an error of law in classifying the fasteners, which were bolts and nuts, sold by the petitioners under item 2 of the Fifth Schedule to the Tamil Nadu General Sales Tax Act, 1959 upto 07.10.1988 and under item 3 of the First Schedule from 08.10.1988 as parts of motor vehicles when, in 119 of the First Schedule as bolts and nuts, the end-use of the product being irrelevant ?"
T.C.(R).Nos.64 and 65 of 2011 are admitted on the following substantial question of law:-
T.C.(R).64 of 2011:-
" Whether the Sales Tax Appellate Tribunal committed an error of law in holding that the bolts and nuts sold by the petitioners were classifiable only under Sl.No.35(iii) of Part D of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 upto 22.01.2000 and thereafter, under Entry 13(ii) of Part DD of the First Schedule to the TNGST Act, 1959 as parts and accessories of motor vehicles instead of holding that the bolts and nuts fall under Entry 6 of Part D of the First Schedule which was a specific entry for bolts and nuts?
T.C.(R).No.65 of 2011:-
" Whether the Sales Tax Appellate Tribunal committed an eror of law in holding that the bolts and nuts sold by the petitioners were classifiable only under Sl.No.35(ii) of Part D of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 read with Section 9(2) of the Central Sales Tax Act, 1956 upto 22.01.2000 and thereafter, under Entry 13(ii) of Part DD of the First Schedule to the TNGST Act, 1959 as parts and accessories of motor vehicles instead of holding that the bolts and nuts fall under Entry 6 of Part D of the First Schedule which was a specific entry for bolts and nuts ?"
2. The assessee is a manufacturer and dealer in Bolts and Nuts, machine tools, iron scrap etc. The bolts and nuts manufactured for use as motor vehicle parts were sold to Automobile manufacturers as well as to dealers in automobile spares. On a verification of the orders placed by the automobile manufacturers, the Assessing Officer came to the conclusion that the items manufactured were against specific description as automobile spares; hence, these items did not come under Entry 119 of First Schedule to the Tamil Nadu General Sales Tax Act, 1959, to be treated as 'common bolts and nuts'. Going by the nature of products thus manufactured and sold, the Assessing Officer rejected the assessee's contention that the item in question fell under Entry 119 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 (hereinafter called as the "TNGST Act"). The Assessing Officer viewed that being automobile parts, they could not be used for purposes other than as automobile parts; hence, in the absence of details filed like Bill Number and date etc., for sales against Form XVII, higher rate of tax at 12% would be adopted and taxable under Entry 3 of the First Schedule to the TNGST Act. The Assessing Officer pointed out that the items supplied by them were "concrod nut", Cylinder head unit, nyloc nut etc, which were manufactured with special designs suited for automobiles only. Pointing out that they would not come under general entry, the Assessing Officer levied tax at 12%. Aggrieved by this, the assessee went on appeal before the Deputy Commissioner (CT) Appeals, who, confirmed the assessment. The assessee, once again went on appeal before the Sales Tax Appellate Tribunal.
3. By order dated 24th March, 2000, the Sales Tax Appellate Tribunal rejected the assessee's contention. Entry 119 of the First Schedule, as it stood during the year 1989-90, reads as follows:
" Bolts, rivets and nuts, threaded or tapped and screws of base metal or alloys thereof, including bolt ends, screw studs, screw studding, self-tapped screws, screw hooks and screw rings".
4. Entry 3, as it stood between 01.01.1988 and 06.10.1988, was as follows:
i) Motor Cars, motor taxi-cabs, motor omni-buses, motor vans, jeeps and motor lorries, chassis or motor vehicles, bodies built on chassis or motor vehicles belonging to others (on the turnover relating to bodies), auto-rickshaws and all the varieties of trailers, by whatever name know;
ii) motor-cycles, motor scooters, moterettes, mopeds, and
iii) bicycles, tricycles, cycle-rickshaws, tandem cycles, cycle combinations and perambulators fitted with motor engines and motor engines used for being fitted thereto ;
iv) tyres including phenumatic tyres, tubes and flaps ordinarily used for motor vehicles and trailers mentioned in sub-items (i) to (iii) above (whether or not such tyres, tubes and flaps are also used for other vehicles). "
(taxable at 8%)
5. Entry 3 of I Schedule from 07.10.1988 reads as follows:
"(i) Motor cars, motor taxi-cables, motor omni-buses, motor vans, jeeps and motor lorries, chassis of motor vehicles, bodies built on chassis of motor vehicles belonging to others (on the turnover relating to bodies). Auto-rickshaws and all the varieties of trailers, but whatever name known;
ii) motor-cycles, motor scooters, motorettes, mopeds;
iii) bicycles, tricycles, cycle-rickshaws, tandem cycle, cycle combinations and perambulators fitted with motor engines and motor engines used for being fitted thereto;
iv) tyres including phenumatic tyres, tubes and flaps ordinarily used for motor vehicles and trailers mentioned in sub-item (i) to (iii) above (whether or not such tyres, tubes (and flaps) are also used for other vehicles);
v) parts and accessories of motor vehicles and trailers excluding batteries. "
(taxable at 12%)
6. Entry 2 of V Schedule reads as follows:
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Sl.No. Description Point of levy and rate of tax (PER CENT) of goods ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ At the At the At the Was in point of point of point of force first sale first sale last sale during the in the in the in the period State to State to a State persons registered other than dealer registered dealers ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ (1) (2) (3.a) (3.b) (3.c) (3.d) ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
2. Parts and 12 8 4 23.03.1987 accessories to of motor- 06.10.1988 vehicles and trailers excluding batteries ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
7. The Sales Tax Appellate Tribunal held that the words "parts and accessories of motor vehicles" was inserted in Entry 3 from 07.10.1988 only as sub-entry (v); there was no entry relating to parts and accessories in the First Schedule for the period prior to 07.10.1988; that the products of the petitioner sold during the relevant time was classifiable as auto parts assessable under Entry 2 of V Schedule, as it stood at the relevant time. Thus, for the period 01.04.1988 to 06.10.1988, in view of Entry 2 of V Schedule, parts and accessories of motor vehicles were assessable at 12% in the case of sales to unregistered dealers, 8% in the case of first sale to registered dealers and at 4% on the last sale with effect from 23.03.1987 to 08.10.1988 under Item 2 of the V Schedule and 8% with effect from 07.10.1988 as falling under Item 2 of the I Schedule. Since the purchasers were registered dealers, the rate of tax would be 8% as contemplated under Entry 2 of V Schedule upto 06.10.1988. As per the circular of the Commissioner of Commercial Taxes dated 12.09.1990, tax on parts and accessories of motor vehicles would be 8% with effect from 07.10.1988. Thus, for the assessment year 1988-89, the rate of tax would be 8% only. Even though the rate of tax under Entry 119 would be the same, yet, the item in question would be assessable only as parts and accessories of motor vehicles. Since there was no difference of tax between Entry 119 as well as Entry 3 of I Schedule and Entry 2 of V Schedule, there was no question of imposing any penalty.
8. Referring to the licence issued by the Government of India, the Sales Tax Appellate Tribunal pointed out that the assessee was manufacturing 'High Tensile bolts and nuts' Set screws and socket head screws and also Rivets. Referring to the letters from the purchasers, who are automobile manufacturers, the Sales Tax Appellate Tribunal pointed out that the automobile manufacturers admitted that bolts and nuts were fitted in their automobile chassis/I.C.engines manufactured in their factories at Ennore and Hosur; it is also admitted that in the purchase orders they had given the items with specific part numbers for identification, inventory, stock handling and for receipts and issues for manufacture. Thus, the Tribunal held that in the face of this evidence, bolts and nuts manufactured and sold by the assessee could not be brought under Entry 119.
9. Referring to the decisions relied on by the assessee viz., PLASMAC MACHINE MGF CO. PVT. LTD VS. COLLECTOR OF CENTRAL EXCISE reported in 1191 (51) E.L.T. 161 (Supreme Court), BHUR INDUSTRIES LTD, BOMBAY VS. COLLECTOR OF CENTRAL EXCISE, BOMBAY reported in (1989) 1 SCC 602, M/S.ASIAN PAINTS INDIA LTD VS. COLLECTOR OF CENTRAL EXCISE reported in (1988) 2 SCC 470, decision of the Bombay High Court in the case of SIMMONS MARSHAL LTD VS. M.RBARALIKAR ASSISTANT COLLECTOR OF CENTRAL EXCISE, PUNE AND OTHERS reported in 1985 (22) E.L.T.378(Bom), The CEGAT, Special Bench 'D', New Delhi in the case of COLLECTOR OF CENTRAL EXCISE, MADRAS VS. SUNDARAM FASTENERS LTD. MADRAS reported in 1985 (22) E.L.T.923 (Tribunal), the Sales Tax Appellate Tribunal held that these decisions had no relevance at all. For understanding the issue, when Entry 119 deals with all 'bolts and nuts' without any exclusion clause and and Entry 3 deals with parts and accessories of motor vehicles without any inclusion clause, the contention of the assessee that by mere naming of the items as bolts and nuts should fall under Entry 119 was rejected by the Sales Tax Appellate Tribunal. The Sales Tax Appellate Tribunal further referred to Entry 3 as excluding batteries and held that in the absence of any exclusive clause as regards 'bolts and nuts' in Entry 3, the claim of the assessee could not be accepted that the product in question would fall under Entry 119. Thus, the Sales Tax Appellate Tribunal rejected the assessee's contention.
10. The Sales Tax Appellate Tribunal further pointed out that there was no difference in rate of tax and for the period from 01.04.1988 to 06.10.1988, there was no specific inclusion of bolts and nuts under Entry 119. Considering the rate similarity, the Sales Tax Appellate Tribunal directed the Assessing Officer to apply 8% rate of tax. Aggrieved by the classification made that the item in question fell under Entry 3, the assessee has filed Tax Case Revision before this Court.
11. Learned counsel appearing for the assessee pointed out that in Circular No.190419/86 dated 22.12.1986, the Special Commissioner and Commissioner of Commercial Taxes clarified that the product in question would be classifiable under a specific entry viz., Entry 119 of the First Schedule to the TNGST Act, 1959, on bolts, rivets and nuts; consequently, the item in question could not be brought under Entry 3. Learned counsel for the assessee took us through Entry 3 and Entry 119 of the First Schedule right from the time, when Entry 3 was introduced in the First Schedule referable to motor vehicles, its parts and accessories. He also referred to Entry 2 of Schedule V relating to the period 01.04.1988 to 06.10.1988. Learned counsel also referred to the subsequent development, in 1965, by way of The Madras General Sales Tax (Amendment) Act, 1965, Act No.7 of 1965, bringing articles (excluding batteries) adapted for use generally as parts and accessories of motor vehicles and trailers under Item 3 of I Schedule and the subsequent amendment in 1974 by way of The Tamil Nadu General Sales Tax (Amendment) Act, 1974, Act No.23 of 1974 bringing under Entry 119 relating to Bolts and nuts, threaded or tapped and screws of base metal or alloys thereof, including bolt ends, screw studs, screw studding, self-tapped screws, screw hooks and screw rings. He referred to the objects and reasons of introduction of Entry 119 and submitted that even though there might be a separate entry for automobile parts and accessories, meaningful interpretation should be given particularly when a separate entry is there for bolts and nuts. He also pointed out that from 01.04.1988 to 06.10.1988, parts and accessories of motor vehicles were kept under Fifth Schedule that the rate of tax was fixed at 8% at the point of first sale to the registered dealers and that of 12% to unregistered dealers. Entry 2 in the Fifth Schedule was added by way of Act 31 of 1987 taking it from item 3 of the First Schedule. Subsequently, Entry under Entry 3 was amended from 07.10.1988 by way of Sub Clause (v) to include parts and accessories of motor vehicles excluding batteries.
12. Learned counsel pointed out that with the specific exclusion of batteries alone in the entries and a specific entry available under Entry 119 dealing with bolts and nuts, the question of treating bolts and nuts as falling under Entry 3 is not sustainable. In this connection, learned counsel placed before us the decision of the Kerala High Court in the case of New Prasanthi Automobiles Co Vs. State of Kerala reported in (1993) 91 STC 565, which related to assessee's Distributor's case.
13. We have gone through the entries and the amendments brought forth and the findings given by the Tribunal. We have no hesitation to hold that there are no merits in the contention of the assessee to reject the reasoning of the order of the Tribunal.
14. Before going into the findings of the Tribunal, we need to look at the decision of the Kerala High Court, which deals with one of the assessee's distributor. The assessee therein was carrying on sales in automobile spare parts, mill stores, hardwares, marine engine spares, rubber goods and tractor parts. The assessee claimed that the sale of items viz., nuts and bolts, (automobile) jacks were assessable at 6 per cent as iron and steel articles and therefore falling under entries 45 or 99 of the First Schedule to the Kerala General Sales Tax Act, 1963. The assessment years under consideration were 1986-87 and 1987-88. The Kerala High Court pointed out that the Tribunal had found that the manufacturer of these goods viz., Sundaram Fasteners Ltd manufactured different types of fasteners which had application in various industries. The Kerala High Court observed as under:-
" 13. It is not in dispute that the nuts and bolts in question are not of any special kind or nature, fitted only for use in automobiles. On the other hand, they are just ordinary nuts and bolts, like any others which could be used for any purpose whatsoever wherever nuts and bolts are required. The Tribunal itself found that the manufacturers of these goods, namely, Sundaram Fasteners Ltd manufactured different types of fasteners which find application in various industries. What we seek to emphasise is that the nuts and bolts in question are not manufactured specially for use as automobile spare parts, but are of general nature liable to be used in any industry."
15. Rejecting the view of the Tribunal, holding that nuts and bolts were not iron and steel articles and based on assessee's nature of business, the Kerala High Court held that the materials produced viz., the nuts and bolts were just like any other nuts and bolts and there was nothing to show that they were exclusively meant for the autombile industry. Thus referring to the decision of the Supreme Court in the case of Ramavatar Budhaiprasad Vs. Assistant Sales Tax Officer (1961) 12 STC 286, in the case of State of West Bengal Vs. Washi Ahmend (1977) 39 STC 378, in the case of Porritts and Spencer (Asia) Ltd Vs. State of Haryana (1978) 42 STC 433 (SC), in the case of Deputy Commissioner Vs. Western India Plywoods (P.)Ltd (1980) 46 STC 331, in the case of Mukesh Kumar Aggarwal & Co., Vs. State of Madhya Pradesh (1988) 68 STC 324, the Kerala High Court held that the items in question were liable to be assessed as Iron and steel articles under entries 45 and 99 respectively of the First Schedule to the Kerala General Sales Tax Act during the relevant period. The Kerala High Court also referred to the note by the Board of Revenue that the Department itself had classified bolts and nuts as falling under Entry 45 of the First Schedule to the Kerala General Sales Tax Act. As far as the question as to whether jack is an accessory to a motor vehicle liable to tax at 15 per cent or an iron and steel article taxable to 6 per cent, the Kerala High Court held that a person seeing an automobile jack is not likely to understand it as a mere iron and steel article. He is likely to understand it only as an adjunct to the automobile necessary for its proper and effective use. He will view it as something which is sold by an automobile dealer and as something which every user of an automobile should necessarily possess. Going by this reasoning, the Kerala High Court rejected the assessee's contention to treat Jack as a mere iron and steel article and not an accessory to a motor vehicle.
16. The present case before this Court merits to be rejected on the same argument as in the case of the Kerala High Court Judgment on automobile jack. It is seen from the findings of the Deputy Commissioner (Appeals) that the entire product i.e., bolts and nuts were sold either to automobile manufacturers or automobile spare parts dealers; the First Appellate Authority pointed out that the bolts and nuts involved in the appeal were exclusively sold to the automobile vehicle manufacturers and auto parts dealers only. In the circumstances, the Deputy Commissioner upheld the order of the Assessing Officer levying tax at 12%.
17. As far as the Sales Tax Appellate Tribunal is concerned, we have already noted the reasoning of the Sales Tax Appellate Tribunal that the evidences available pointed out that the nuts and bolts were manufactured as per the specifications of the automobile manufacturers and that the supplies were made by the assessee as against Form XVII declaration to M/s.Ashok Leyland Ltd., who used these items as components in the manufacture of vehicles. The Sales Tax Appellate Tribunal further pointed out to the argument of the assessee that the function of fasteners and the intrinsic nature of bolts and nuts being fastening, the same would attract Entry 119, which is the specific entry on bolts and nuts in contrast to General Entry 3. Rejecting such view, the Sales Tax Appellate Tribunal found that once the article was designed, made to order with specifications for being used only in automobile, then the specific entry 3 which deals with automobile parts would be relevant entry for the purpose of attracting levy. Rejecting the reliance placed on the Commissioner's classification, the Sales Tax Appellate Tribunal held that the items in question would fall only under Entry 3, however, since parts and accessories was not included from 01.04.1988 to 06.10.1988 and was brought under Fifth Schedule and thereafterwards restored to the First Schedule upto 06.10.1988, the rate of tax will be 8%. Thus, with the finding of the fact that they are automobile parts, we do not find any justifiable ground to accept the plea of the assessee that the item in question would fit in to fall under only Entry 119 and not under Entry 3.
18. It may be pointed out that learned counsel for the assessee placed before us the list of purchasers only to point out that there was textile industries, who also had made purchases from the assessee. Hence, inference could be drawn that bolts and nuts were also used in textile industry. We fail to understand how by going through the name of the purchaser, one can come to the conclusion that bolts and nuts manufactured by the assessee had multifarious functions. There is absolutely no relevant material to substantiate his contention.
19. Entry 3 of First Schedule, as amended by Act No. 7 of 1965, reads as under:-
" 3. Motor vehicles including motor cars, motor taxi-cabs, motor cycles and cycle combinations, motor scooters, motorettes, motor omnibuses, motor vans and motor lorries, chassis of motor vehicles, bodies built on chassis of motor vehicles belonging to others (on the turnover relating to bodies), component parts of motor vehicles, all varieties of trailers, by whatever name known, tyres (including pneumatic tyres) and tubes ordinarily used for motor vehicles and trailers (whether or not such tyres and tubes are also used for other vehicles), and articles (excluding batteries) adapted for use generally as parts and accessories of motor vehicles and trailers."
Entry 55, which deals with all varieties of tractors and bull-dozers was also amended and on reading of both these entries, we may find that specific exclusions as far as batteries alone.
20. By Act 23 of 1974, which is yet another amendment under which, Entries 119 in the Schedule were expanded, which reads as under:-
"119 . Bolts and nuts, threaded or tapped and screws of base metal or alloys thereof, including bolt ends, screw studs, screw studding, self-tapped screws, screw hooks and screw rings."
21. Fifth Schedule, which was introduced under Section 3(2-A) of the Tamil Nadu General Sales Tax Act contained Entry 2 relating to parts and accessories of motor vehicles added to the said Schedule effective from 22.03.1987 to 06.10.1988. By Act 31 of 1987, the said entry was deleted from this schedule and with effect from 07.10.1988, the said entry was once again restored to First Schedule under sub clause (v) of Item 3. The rate of tax as already pointed out from 01.04.1988 to 06.10.1988 was 8%, if it was sold to the registered dealer and 12% in case of sales to other than registered dealers. Entry 119 relating to bolts and nuts remained the same overall, attracting tax at 8%. Apparently, the parity in rate did not bring any kind of difficulty for the assessee in accepting the assessment. The difficulty started only when disparity in rate of tax was brought in. With the result, the assessee contended that in the wake of specific Entry 119 relating to bolts and nuts, even though a specific entry for motor vehicles including parts and accessories of motor vehicles and trailers excluding batteries was there, it is only Entry 119, which is specific entry to bolts and nuts, relevant to the case.
22. The concept of specific entry under Entry 119 in the face of Entry 3 fails in its application in this case, since a reading of the Entry 119 would show that it applies to all nuts and bolts of general nature. When Entry 3 makes a specific reference to articles (excluding batteries), used as spares of motor vehicles, one has to give the necessary emphasis to this phrase "the parts and accessories", which are adapted for the use in automobiles. Even though bolts and nuts generally might have fallen in under Entry 119 of I Schedule, once customised for use in motor vehicles as parts and accessories, the same would only fall under Entry 3 of the First Schedule.
23. The Sub Entry is a user oriented entry for the purpose of fixing the liability. In contrast to the normal theories available in the matter of interpretation of the entry, particularly, the entries relating to the general goods, when Entry 3 under I Schedule is clear that nuts and bolts as part and accessory are manufactured for use in automobiles excluding batteries and brought under Entry 3, we do not subscribe to the contention of the assessee that Entry 119 is a specific entry and hence, nuts and bolts, parts manufactured by the assessee, even though they are automobile parts, would nevertheless fall under Entry 119. Entry 119, in fact, is a general enumeration of goods for the purpose of identification and the rate of tax. Once the item in question viz., "bolts and nuts" is customised for use as parts and accessories of motor vehicle and trailers, the relevant entry herein would be the specific entry viz., Entry 3 of I Schedule of the Tamil Nadu General Sales Tax Act. 1959.
24. In the light of the above, we have no hesitation in rejecting the assessee's appeal. Accordingly, the Tax Case Revision No.2308/2008 stands dismissed. No costs.
25. As far as the other two assessment years are concerned, viz., TNGST 1999-2000 and CST-1999-2000, the question raised is identical one as raised before this Court as that of the earlier mentioned tax case. The Sales Tax Appellate Tribunal in the said cases, following the earlier order in assessee's own case rejected the assessee's appeal. Hence, following the order passed by us in T.C.(R).No.2308 of 2008, we have no hesitation in rejecting the tax case revisions. Accordingly, T.C(R).Nos.64 and 65 of 2011 are also dismissed. No costs.
nvsri To
1.The Assistant Commissioner (CT) Central Assessment Circle-I No.6, Greams Road, Chennai-600 006
2.The Deputy Commissioner (CT), Coimbatore
3.The Sales Tax Appellate Tribunal, Main Bench Chennai