JUDGMENT V. Gopala Gowda, J. - These appeals are filed by the appellant - contractors questioning the correctness of the revisional order passed by the revisional authority in No. ZAC/I/DVG/SMR-11/08-09/T/MP/1099/08-09, dated January 31, 2009 and order dated October 20, 2008 in No. ZAC-I-DVO-1 and 3/SMR/CR-09/08-09, in exercise of power under section 22A(1) of the Karnataka Sales Tax Act, 1957 (in short, "the Act") framing number of substantial questions of law in the appeals, urging various grounds in support of the same and requested to answer the same in favour of the appellants. Since in all these appeals, the questions of law framed are same, on the request made by the learned counsel for the parties, we have heard these appeals together and dispose of by this common judgment. Though number of substantial questions are framed in these appeals in view of the decision of the Supreme Court in the case of State of Andhra Pradesh v. Larsen & Toubro Ltd. reported in [2008] 17 VST 1 only the relevant questions which would arise, for our consideration are extracted hereunder : "(1) Whether the resale tax levied by the respondent under section 6B of the Act considering that the amounts paid by the appellant to the sub-contractor as representing turnover of deemed sale of goods is legally justified ? (2) Whether the respondent is legally justified in levying resale tax under section 6B of the Act acting contrary to the law laid down in the decision of the honourable apex court in the case of State of Andhra Pradesh v. Larsen & Toubro Ltd. [2008] 17 VST 1 ?" On December 19, 2008, this court framed the following substantial questions of law in STA Nos. 20 to 22 of 2008 : "(1) Whether, on the facts and in the circumstances of the appellant's case, was the revisional authority right in holding that the appellant was liable to resale tax under section 6B of the Act, in so far as the payments made to the sub-contractor ? 20 to 22 of 2008 : "(1) Whether, on the facts and in the circumstances of the appellant's case, was the revisional authority right in holding that the appellant was liable to resale tax under section 6B of the Act, in so far as the payments made to the sub-contractor ? (2) Whether, on the facts and in the circumstances of the appellant's case, was the revisional authority right in law in placing reliance upon the judgment rendered by this honourable court in the case of Larsen and Toubro Limited [2008] 16 VST 616; [2006] 61 KLJ 90, when this honourable court in the said case was concerned with the provisions of section 6B of the Act, when the same provided for the levy of turnover tax and not resale tax ?" The learned counsel for the appellants placed strong reliance upon the budget speech delivered by the honourable Chief Minister and Finance Minister on the floor of legislative assembly on March 21, 2002 for the budget year 2002-03 in which the object of introducing section 6B in the Act is mentioned. Sri R. V. Prasad, learned counsel for the appellants in STA Nos. 20, 21 and 22 of 2008 placed reliance upon the decision of the Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. Commissioner of Income-tax reported in [1975] 101 ITR 234 at page 252 in support of his legal submission that the courts have recognised the budget speech presented by the Minister of Finance as a statute in aid for interpretation of fiscal statutes. The purpose of accepting the budget speeches presented by the Finance Ministers is only to understand the intent behind bringing new provisions to fiscal statutes in the Bills to be presented subsequently. The purpose of accepting the budget speeches presented by the Finance Ministers is only to understand the intent behind bringing new provisions to fiscal statutes in the Bills to be presented subsequently. Further he has placed reliance upon another decision of the Supreme Court in the case of K. P. Varghese v. Income-tax Officer reported in [1981] 131 ITR 597 in support of legal contention that the speeches made by the members of legislative assembly on the floor house when a Bill for enacting statutory provisions is being debated are inadmissible for interpretation of statutory provisions but the speech made by the mover of the Bill explaining the reason for the introduction of the Bill can certainly be referred to for the purpose of ascertaining the object, intent and purpose for which the legislation is being enacted to rectify the mistake of ambiguity in the provision in a statute. Further, both the learned counsel Sri Keshavamurthy and Sri R. V. Prasad for the appellants in these appeals have placed strong reliance upon the decision of the Supreme Court in the case of State of Andhra Pradesh v. Larsen & Toubro Ltd. reported in [2008] 17 VST 1 in support of legal contention that in view of article 366(29A)(b) of the Constitution of India, once the work is assigned by the contractor to sub-contractor, the only transfer of property in goods is by the sub-contractors, who is a registered dealer in this case and who claims to have paid taxes under the Act on the goods used for the execution of the works. Once the work is assigned by L & T to its sub-contractors, L & T ceases to execute the works contract in the sense contemplated by article 366(29A)(b) because property passes by accretion and there is no property in goods with the contractor which is capable of retransfer, whether as goods or in some other form. There is no resale by the contractor in favour of sub-contractor. Therefore, the counsel request this court to answer the questions of law framed in favour of appellant - assessees. Ms. There is no resale by the contractor in favour of sub-contractor. Therefore, the counsel request this court to answer the questions of law framed in favour of appellant - assessees. Ms. Geetha Menon, learned Additional Government Advocate placing strong reliance upon the statutory provisions of section 6B read with rule 6(m) and 6(n) of the Karnataka Sales Tax Rules, 1957, sought to justify the impugned orders contending that the revisional authority has rightly set aside the first appellate authority's order and restored the assessing authority's order and the same is in conformity with the Division Bench decision of this court in the case of Larsen & Toubro Limited, Bangalore v. Addl. Deputy Commissioner of Commercial Taxes (Assessments 14), Bangalore, City Division I, Bangalore reported in [2008] 16 VST 616; [2006] 61 Kar. L.J. 90 (HC) (DB), wherein the Division Bench of this court has held that turnover tax is leviable at the hands of both contractor and sub-contractor. Therefore, the findings and reasons recorded by the revisional authority for reversing the order of the first appellate authority and passing assessment orders against the assessee are legal and valid. Therefore, she submitted that the substantial questions of law framed in this judgment do not arise for consideration by this court and requested to dismiss these appeals. In view of rival legal contentions, we have to consider whether the substantial questions of law framed arise for consideration and the same are required to be answered in favour of the appellants. Our answer to the aforesaid substantial questions of law is in the affirmative and are answered in favour of the appellant - assessees for the following reasons : From the show-cause notice issued to the appellants, it is seen that the assessing officer proceeded on the assumption that there is resale of goods in favour of sub-contractor by the contractor. Resale is evident from the contents of show-cause notices, the assessing orders and also in the revisional authority's order. The object and intendment of inserting section 6B in the Act by way of amendment to the KST Act with effect from April 1, 2002 has been explicitly made clear in the budget speech delivered by the honourable Chief Minister and Finance Minister while presenting the budget for the year 2002-03, reads thus : "177. VAT entails multi-point levy of tax at all points of production and distribution. VAT entails multi-point levy of tax at all points of production and distribution. The second and subsequent dealers in the trade channel who are currently paying a nominal non-passable turnover tax of one per cent would have to pay tax under VAT which could be higher but collectable. As an intermediate measure and to prepare deals for a smooth transit to VAT, I propose to introduce a collectable resale tax of 1.5 per cent. Most of the commodities which are totally exempt from tax on their second and subsequent sales, however, are proposed to be exempt from this new levy. This collectable new levy should induce the entire trade to issue bills on all their sales". A careful reading of the above portion of the speech made by the Finance Minister of Karnataka State makes it clear that section 6B of the Act was inserted with a view to bring second or subsequent sale of goods under tax umbrella. The learned counsel for the appellants rightly relied upon the judgment referred to supra to construe the speech delivered by honourable Finance Minister as statute for the purpose of ascertaining the object and intendment of inserting section 6B to the statute. It is an undisputed fact in all these cases there is a registered sub-contractor to whom the work is entrusted by the appellant - contractors. It is not the case of Revenue that the sub-contractor is not a registered dealer under section 10 of the KST Act and not paid the tax on taxable turnover in respect of transfer of goods for the execution of work in favour of contractor. The case of the Revenue, placing reliance upon the Division Bench judgment of this court, namely, Larsen and Toubro Limited v. Addl. Deputy Commissioner of Commercial Taxes [2008] 16 VST 616; [2006] 61 KLJ 90, is that tax is leviable at multi-point, viz., both at the hands of main contractor and sub-contractor. Therefore, the assessment order passed against the appellant - assessee under section 6B is justifiable. This is the case sought to be made out by the learned Additional Government Advocate on behalf of Revenue. Therefore, the assessment order passed against the appellant - assessee under section 6B is justifiable. This is the case sought to be made out by the learned Additional Government Advocate on behalf of Revenue. The observation made at paragraph 9 in this regard by the Division Bench is not the correct position of law in view of recent judgment of the apex court in the case of State of Andhra Pradesh v. Larsen & Toubro Ltd. [2008] 17 VST 1 upon which the learned counsel for the appellants have rightly placed reliance in support of their legal contentions. The apex court has framed the question at clause item 17 of the said judgment (i.e., State of Andhra Pradesh v. Larsen & Toubro Ltd.) [2008] 17 VST 1 which reads thus : "... whether the turnover of the sub-contractors (whose names are also given in the original writ petition) is to be added to the turnover of L & T. In other words, the question which we are required to answer is whether the goods employed by the sub-contractors occur in the form of a single deemed sale or multiple deemed sales. In our view, the principle of law in this regard is clarified by this court in the case of Builders Association of India [1989] 73 STC 370 (SC) as under : 'Ordinarily unless there is a contract to the contrary in the case of works contract the property in the goods used in the construction of a building passes to the owner of the land on which the building is constructed, when the goods or materials used are incorporated in the building'." It would be necessary for us to extract the relevant observation made by the apex court at para 16 after interpreting section 47A of the Andhra Pradesh Value Added Tax Act, 2005 read with rule 17(1)(a) and (c) and article 366(29A)(b) of the Constitution of India, which reads thus : "... Under section 4(7)(a) read with rule 17(1)(c), quoted above, where a VAT dealer awards any part of the contract to a sub-contractor, such sub-contractor shall issue a tax invoice to the contractor for the value of the goods at the time of incorporation in such subcontract. The tax charged in the invoice issued by the sub-contractor shall be accounted by him in his returns. The tax charged in the invoice issued by the sub-contractor shall be accounted by him in his returns. Therefore, the scheme indicates that there is a 'deemed sale' by the dealer executing the work, i.e., the sub-contractor. It is only the sub-contractor who effects transfer of property in goods as no goods vests in the respondent - company (contractor) so as to be the subject-matter of a retransfer. By virtue of article 366(29A)(b) of the Constitution once the work is assigned by the contractor (L & T), the only transfer of property in goods is by the sub-contractors who is a registered dealer in this case and who claims to have paid taxes under the Act on the goods involved in the execution of the works. Once the work is assigned by L & T to its sub-contractors, L & T ceases to execute the works contract in the sense contemplated by article 366(29A)(b) because property passes by accretion and there is no property in goods with the contractor which is capable of a retransfer, whether as goods or in some other form." In paragraph 17 with reference to Builders Association case [1989] 73 STC 370 (SC), the following relevant portion is extracted : "The question which is raised before us is whether the turnover of the sub-contractors (whose names are also given in the original writ petition) is to be added to the turnover of L & T. In other words, the question which we are required to answer is whether the goods employed by the sub-contractors occur in the form of a single deemed sale or multiple deemed sales. In our view, the principle of law in this regard is clarified by this court in the case of Builders Association of India [1989] 73 STC 370 (SC) as under : 'Ordinarily unless there is a contract to the contrary in the case of works contract the property in the goods used in the construction of a building passes to the owner of the land on which the building is constructed, when the goods or materials used are incorporated, in the building'." From Builders Association of India case [1989] 73 STC 370 (SC) at paragraph 19, the following portion is extracted : "If one keeps in mind the above quoted observation of this court in the case of Builders Association of India [1989] 73 STC 370 (SC), the position becomes clear, namely, that even if there is no privity of contract between the contractee and the sub-contractor, that would not do away the principle of transfer of property by the sub-contractor by employing the same on the property belonging to the contractee. This reasoning is based on the principle of accretion of property in goods. It is subject to the contract to the contrary. Thus, in our view, in such a case the work executed by a sub-contractor, results in a single transaction and not as multiple transactions. This reasoning is also borne out by section 4(7) which refers to value of goods at the time of incorporation in the works executed. In our view, if the argument of the Department is to be accepted it would result in plurality of deemed sales which would be contrary to article 366(29A)(b) of the Constitution as held by the impugned judgment of the High Court. Moreover, it may result in double taxation which may make the said 2005 Act vulnerable to challenge as violative of articles 14, 19(1)(g) and 265 of the Constitution of India as held by the High Court in its impugned judgment." The relevant portions of the apex court judgment which were extracted above, with all fours, applicable to the fact-situation of the present cases. On the other hand, reliance placed by the learned Additional Government Advocate upon the Division Bench judgment of this court has no application to the fact-situation, hence, the same is rejected. For the reasons stated supra, we answer the substantial questions of law in favour of the appellant - assessee. On the other hand, reliance placed by the learned Additional Government Advocate upon the Division Bench judgment of this court has no application to the fact-situation, hence, the same is rejected. For the reasons stated supra, we answer the substantial questions of law in favour of the appellant - assessee. In the result, the appeals are allowed. The orders passed by the revisional authority and also the assessing officer are hereby set aside.