Order G.C Bharuka, J. These two reference, brought before this Court under Section 33(2) of the Bihar Sales Tax Act, 1959, (In short 'the Act' only), relate to the financial years 1972-73 and 1973-74 and involve the following common questions : (i) Whether the stitching of the uniforms by the petitioner involves any element of sale; (ii) Whether on the facts and circumstances of the case, the petitioner can be held to be liable for sales tax on the sale of the uniforms; (iii) Whether in the facts and circumstances of the case, the petitioner is liable to sales tax for the sale of cooked food. 2. The assessee, Sonary Community and Welfare Centre is a registered dealer under the provisions of the Act and, inter alia, carries on business in tailored uniforms and cooked food. During the assessment proceedings for the periods in question, the assessee claimed deductions in respect of sale of tailored uniforms and cooked foods. But the same was disallowed by the assessing officer. His appeal to the Deputy Commissioner as also the revision to the Tribunal failed. Therefore, the present references have been brought for the opinion of this Court on the questions, as quoted above. 3. The first two questions relate to the sale of tailored uniforms. According to the case of the assessee, they have entered into an agreement with the Tisco for stitching and supplying uniforms for their employees as per specifications and by using the materials supplied by them. Therefore, according to the assessee, the transaction was only of employing labour and there was no sale element involved in it attracting any sales tax under the Act. The claim was examined by the Assessing Officer with reference to all the documents on record and concluded that the assessee, in fact, supplies ready-made garments to Tisco, the sale price whereof includes the cost of raw materials as well as the stitching charges. According to him mere drawing of bills showing the cost of materials and stitching charges separately can not change the nature of transaction because whether the price of the uniforms is shown component-wise or in a consolidated form, the sum total is the sale price of the goods. The Tribunal also, on due consideration of all the relevant materials, has recorded a finding of fact in these terms : "As a matter of fact, he was purchasing cloths, buttons etc. The Tribunal also, on due consideration of all the relevant materials, has recorded a finding of fact in these terms : "As a matter of fact, he was purchasing cloths, buttons etc. from suppliers as per instructions from TISCO and then supplying the uniforms after stitching. He was, thus actually supplying readymade garments to Tisco, and he was thus liable to pay sales tax under the Act." 4. The third question relates to the sale of cooked food. According to the assessee, it was running a canteen only for the welfare of the members of certain employees of Tisco and was not running a regular business and, therefore, such sales are not liable to sales tax. It is not in dispute that the assessee and Tisco are two different legal entities and the assessee had undertaken to run the canteen as a measure of profit for the benefit of its own members. Admittedly the assessee is a registered dealer. The Tribunal has recorded a definite finding of fact to the effect that : "Since he was selling cooked foods and as the gross turnover during the previous financial year exceeded Rs. one Lakh, he was liable to pay sales tax." 5. Nothing has been placed before us to show that findings of facts recorded by the Tribunal suffers from any infirmity in the sense that those have been recorded either without taking into consideration any relevant material or by taking into consideration any irrelevant materials or even otherwise are perverse on any other ground. 6. The findings relating to the question involved being that of pure facts, according to us, it is incompetent on the part of this Court to render any opinion in respect of the question involved since the said findings being that of facts should be deemed to have attained their finality. 7. In its advisory jurisdiction under Section 33 of the Act, this Court can give its opinion only on question of law arising out of the order of the Tribunal. This is a special jurisdiction circumscribed by the Conditions and Qualifications prescribed by the legislature (refer State of Bihar vs. Arthur Butler, 7 STC, 379). 8. The two references are, accordingly, rejected as being incompetent. There will be no order as to costs. Aftab Alam, J. - I agree.