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1. Messrs Nilgiri Ceylon Tea Supplying Co. carry on business as dealers in tea in Bombay. They have been registered dealers under the Bombay Sales Tax Act, 1953. Messrs Nilgiri Ceylon Tea Supplying Co. who will be hereafter referred to as "the assessees" purchased diverse brands of tea and without the application of any mechanical or chemical processes mixed up the brands of tea purchased in bulk by them and sold the tea as tea mixture. The mixing, however, is not haphazard but according to the formula which was evolved by the assessees. In the assessment of sales tax the assessees claimed that the value of the tea purchased by them should be deducted from the turnover under section 8 of the Bombay Sales Tax Act, 1953. The Sales Tax Authorities did not accept the contention of the assessees having regard to the proviso to clause (a) of section 8 and did not allow deduction for the value of the tea purchased out of the turnover. The Sales Tax Tribunal also affirmed the view of the Sales Tax Authorities. The Sales Tax Tribunal has at the instance of the assessees, referred the questions :