Rajes Kumar, J. - (1.) These two revisions under Section 11 of U.P. Trade Tax Act (hereinafter referred to as "Act") are directed against the orders of Tribunal dated 11.09.1998 both relating to the assessment year 1989-90 under the U.P. Trade Tax Act as well as under the Central Sales Tax Act respectively.
(2.) In both the aforesaid revisions, following two common questions have been raised: (a) Whether on the facts and in; the circumstances of the case, the sales of tinned fresh fruits and green vegetables were liable to tax? (b) Whether on the facts and in the circumstances of the case, the process of preservation and tinning of fresh fruits and green vegetables could be described as manufacture as defined under Section 2 (e-1) of the U.P. Trade Tax Act?
(3.) Heard learned Counsel for the parties.;