(1.) The question involved herein, which is of frequent occurrence, is whether a particular transaction is a contract for work and labour or outright sale.
(2.) These two cases involving common point and the assessee being common, could be disposed of by a common order. T.R.C. No. 47 of 1981 pertains to the assessment year 1975-76 and T.R.C. No. 46 of 1981 is for the assessment year 1976-77. The findings of the Appellate Tribunal are :
(3.) It was further held that :