JUDGMENT RAJES KUMAR, J. - These three revisions arise from the order of the Tribunal dated December 9, 2002 for the assessment years 1996-97, 1992-93 and 1989-90. The opposite party is the UPSRTC, Azamgarh operates buses and engaged in extending the services of transportation of the passengers from one place to another place. During the year under consideration, the opposite party had entered into the contract with some parties for the transportation of passengers from one place to another place on contracted amount. The assessing authority levied the tax on such contracted amount (transportation charges) under section 3F of the U.P. Trade Tax Act, 1948 ("the Act") on the ground that there was transfer of right to use the buses. The claim of the opposite party was that the buses were provided only for the transportation of the passengers in which the driver and conductor were of the corporation and the expenses towards the diesel and other expenses were borne by the corporation and the possession of the buses was never given to any party at any point of time and the control over the buses was always with the corporation. The first appellate authority accepted the plea of the opposite party and deleted the tax. The Commissioner of Trade Tax filed the appeals before the Tribunal. The Tribunal by the impugned order rejected the appeals and confirmed the order of the first appellate authority. Heard Sri K. M. Sahai, the learned Standing Counsel and Sri Sameer Sharma, learned counsel for the opposite party. The learned Standing Counsel submitted that under the contract, the buses were provided for use to the parties with whom the corporation entered into the contract and, therefore, it amounts to transfer of right to use the buses. Sri Sameer Sharma, the learned counsel for the opposite party submitted that under the contract at no point of time the possession of the buses was given and they were always with the corporation. He submitted that under the contract only the passengers were transported from one place to another place as desired by the parties on the contracted amount. The drivers and conductors were of the corporation and all running expenses, etc., were borne by the corporation. Heard learned counsel for the parties. I have also perused the order of the Tribunal and authorities below. The drivers and conductors were of the corporation and all running expenses, etc., were borne by the corporation. Heard learned counsel for the parties. I have also perused the order of the Tribunal and authorities below. The Tribunal found that the possession of the buses was never given to the parties with whom the corporation entered into the contract and the buses were always under the control and possession of the corporation. The conductors and drivers were of the corporation. The finding of the Tribunal is finding of fact. The learned Standing Counsel is not able to show anything to the contrary. He is not able to show that any point of time the possession and control of the buses were given by the corporation to any party. In the case of Bharat Sanchar Nigam Ltd. v. Union of India reported in [2006] 145 STC 91; [2006] 3 VST 95; [2006] 29 NTN 307, the apex court held that for the transfer of right to use the goods the goods must be in a deliverable stage and at some stage it must be delivered. The delivery of the goods at some stage is the sine qua non for being a transaction of transfer of right to use. In view of the above, revisions have no merit and all the three revisions fail and are dismissed.