SINGH, J. - (1.) The Revising Authority, Kanpur, has referred the following question of law for the opinion of this Court : " Whether, on the facts and in the circumstances of the case, the framing of pictures amounted to 'sales' within the meaning of the Act and liable to tax as such ?" The reference is being treated as a revision in view of the amendment in the law. The facts to dispose of the revision are very short. The assessee framed pictures for its customers and charged a consolidated amount for labour and for material used in framing pictures. The revising authority has held that the work done by the assessee was of a composite nature, viz. , supplying the material used in framing pictures, and spending labour for doing so. This being so, the transaction in question was not a sale of picture-frames to its customers, but a works contract. The view taken by the revising authority is justified on the facts found. The revision fails and is dismissed. The assessee is entitled to its cost, which is assessed at Rs. 200. Petition dismissed. .;