ORDER : C.Praveen Kumar, J. Heard Sri S. Dwarakanath, learned counsel for the petitioner, and Sri T.C.D. Sekhar, learned Government Pleader for Commercial Tax appearing for the respondent, and perused the record. 2. Since the issue involved in all these cases is one and the same, they are disposed of by this common order. 3. T.R.C.Nos.15, 16 and 159 of 2003 are filed under Section 22(1) of the Andhra Pradesh General Sales Tax Act, 1957 (for short, “APGST Act”) assailing the order, dated 23.10.2002, in T.A.No.607 of 1999, T.A.No.996 of 2001 and T.A.No.609 of 1999 respectively on the file of the Sales Tax Appellate Tribunal, Andhra Pradesh, Hyderabad (for short, “the Tribunal”), wherein the Tribunal rejected the claim of the dealers claiming exemption from payment of tax. 4. T.R.C.No.15 of 2003 is taken as a lead case to decide the issue involved. The facts of this case, in brief, are as under:- The petitioner/appellant is a registered dealer on the rolls of Commercial Tax Officer, Aryapuram Circle, Rajahmundry dealing in manufacture of wooden furniture. He was assessed by the Commercial Tax Officer under CST Act for the year 1994-1995 vide proceedings, dated 12.03.1996, on a total turnover of Rs.21,69,630/-and net turnover of Rs.1,980/-, by allowing the exemption on a turnover of Rs.21,67,650/-and the total tax due being Rs.198/-. On a scrutiny of the said assessment record, the Deputy Commissioner focused that the assessing authority allowed exemption on a turnover of Rs.21,67,650/-in terms of G.O.Ms.No.256 (Rev), dated 11.02.1958 read with Section 8(2A) of the CST Act, 1956, being sales of wooden furniture to the Military Department. But as the sale of wooden furniture to the dealer, is for providing accommodation (infrastructure) to the officials and other persons employed under the military organizations, the Deputy Commissioner, in exercise of powers under Section 20(2) of the APGST Act, revised the assessment withdrawing the exemption granted and subjected the turnover to tax treating it as unclassified goods. But as the sale of wooden furniture to the dealer, is for providing accommodation (infrastructure) to the officials and other persons employed under the military organizations, the Deputy Commissioner, in exercise of powers under Section 20(2) of the APGST Act, revised the assessment withdrawing the exemption granted and subjected the turnover to tax treating it as unclassified goods. In other words, the Deputy Commissioner has held that the said G.O. is not applicable to the transactions made by the dealer with military organizations i.e., Military Engineering Services, because as per the said G.O., the sales of provisions and other goods at Military Farms, Officers shops, Supply Depots and Canteens established for Military personnel sold by prices fixed by the Government of India, are exempt from the tax payable under the APGST Act but not sales to those organizations. Since the Military Engineering Services is not one of those organizations enumerated in the G.O., held that the assessing authority wrongly granted exemption under the said G.O. Holding so, the Deputy Commissioner issued revised show cause notice, dated 31.10.1998, to the petitioner herein to file written objections, if any, against the revision of assessment proposed, within two weeks from the date of receipt of that notice failing which, orders would be passed accordingly without any further notice. Objections came to be filed by the dealer disputing the contents in the show cause notice and also raised a plea that if the contents of G.O.Ms.No.256 are not applicable to the case of the petitioner, the transactions covered by the disputed turnover relate to works contract, as furniture is made as per the contract with Military Engineering Services (MES). Thus, the plea taken before the revisional authority was that it was only execution of works contract for making furniture and not sale of furniture and as such, not liable to sales tax under CST Act. Taking into consideration the objections raised, the Deputy Commissioner of Commercial Taxes, Kakinada, vide his order, dated 24.02.1999, confirmed the revision of assessment by withdrawing the exemptions allowed on turnover of Rs.21,67,650/-by the C.T.O. Aggrieved by the same, the appellant preferred appeal before the Sales Tax Appellate Tribunal raising the very same pleas which are raised before the revisional authority. After hearing the arguments of both the parties, the Tribunal, by order, dated 23.10.2002, dismissed the appeal against which, the present Tax Revision Case is filed. 5. After hearing the arguments of both the parties, the Tribunal, by order, dated 23.10.2002, dismissed the appeal against which, the present Tax Revision Case is filed. 5. Sri S. Dwarakanath, learned counsel for the petitioner, mainly submits that a close perusal of G.O.Ms.No.256 would clearly indicate that the petitioner is entitled for exemption of payment of tax for the reason that the word “at” if read as “to”, it would mean that the sales made to military farms, Officers shops, Supply Depots and canteens established for military personnel would be exempted from payment of tax. He further submits that even otherwise the transaction between the petitioner and the military services has to be treated as a works contract since the goods are supplied pursuant to an order placed in specifications. 6. The same is opposed by Sri T.C.D. Sekhar, learned Government Pleader for Commercial Tax appearing for the respondent, contending that there is no necessity to substitute the word “at” in the said G.O. since a reading of the same clearly indicates that only products sold at the military canteen or at military farms or officers’ shops, supply depots and canteens established for military personnel would only get exemption, if any, and not by the person who supplies goods “to” military farms, officers shops and canteens. In the absence of any ambiguity in the G.O., question of substituting the word “at” with “to” would not arise. He would further contend that a reading of the contract does not anywhere indicate to be a contract for works but an outright sale of movables for a fixed price. In view of the above, he submits that there are no merits in this case and the same is liable to be dismissed. 7. Insofar as the first point namely as to whether the goods of the petitioner are covered by G.O.Ms.No.256, it would be appropriate to extract the said G.O., which reads as under :- “In exercise of the powers conferred by Sub-Section (1) of Section 9 of the APGST Act, 1957 (APGST Act VI of 1957), the Governor of Andhra Pradesh hereby exempts from the tax payable under the said Act the sales of provisions and other goods at Military Farms, Officers shops, Supply depots and Canteens established for Military personnel *(provided that the provisions and other goods are sold by prices fixed by the Government of India). This notification shall be deemed to have come into force on the 15th June, 1957”. A reading of the said G.O. would disclose that the said G.O. is made applicable to such organizations which are specifically mentioned in the said G.O. and the said G.O. covers the sales of provisions and other goods at Military Farms, Officers shops, Supply depots and Canteens which are established for military personnel. As stated earlier, learned counsel wanted the word “at” to be read as “to”, covering the sales made to military farms. We are not inclined to accept the same. Substitution of any word, if it changes the entire meaning of the G.O., cannot be adopted. The word “at” indicates sales made at the place in Military Farms, Officers’ Shops etc. In other words, it covers only sales made by military farms, canteens etc., to the military personnel and not to sales made by dealers. If the word “to” is replaced with “at”, it covers cases of persons supplying goods to Military Farms, Officers’ shops etc., which is not the purport of the said G.O. This could not have been the intention of the Government by any stretch of imagination. Having regard to the above, the finding given by the Tribunal as well as by the appellate/revisional authorities cannot be said to be illegal and the same warrants no interference of this Court. 8. Coming to the next point namely as to whether the transaction is to be treated as a works contract and not an outright sale of movables for a fixed price, it is to be noted that the plea taken before the Deputy Commissioner is that the transactions are to be treated as works contract. It was pleaded that the petitioner signed agreement with the Military Engineering Services which is a Military Organization of Central Government, for supply of items of furniture as is specifically mentioned in the Tender Acceptance letters and they were manufactured after the contract was signed, confirming strictly to the specifications mentioned in the agreement. Learned counsel took us through various clauses of the agreement to show that it is only a works contract and not a sale made to an order. 9. Learned counsel took us through various clauses of the agreement to show that it is only a works contract and not a sale made to an order. 9. A perusal of Clause 8 of the contract would show that Schedule A contains description and serial number of the item to be manufactured and the contractor has to supply samples in the first instance for approval of the Engineer-in-charge and after approval of the sample, the dealer has to go ahead with the manufacturing process. Similar requirement is mentioned in respect of material mentioned in schedule. Clause 8 also postulates that the contractor shall use his own material for making the furniture items by getting it himself. Further, Government agreed to supply certain items for making items in Schedule B at the rate mentioned therein, if the contractor so wishes by exercising option for the same while submitting tenders. From the above, it is clear that the contractor is incurring the cost of material used in the manufacture of furniture items and that the material is not supplied by the Government free of cost. Further, conditions of payment are specified in Condition No.33. Be that as it may, Clause 8-C of General Conditions, which assumes significance, states that materials when they are lying on the site become the property of the Government and when they are removed from the site, they again become the property of the contractor. A reading of the conditions of the contract, which are not disputed by the petitioner, would indicate that the understanding between the petitioner and the Government is an outright sale of movables for a fixed price. 10. Having regard to the above and in view of the judgment of the Hon’ble Supreme Court in M/s. Hindustan Shipyard Limited vs. State of Andhra Pradesh, (2000) 31 APSTJ, it cannot be said that the transaction is a works contract and that the petitioner is liable for the exemptions therein. Hence, we see no ground to interfere with the order impugned. 11. At this stage, learned counsel for the petitioner would submit that the petitioner herein filed certificates in Form “D” claiming exemptions but the same were not considered by the authorities. 12. It is to be noted here that the Deputy Commissioner, in the order, dated 24.02.1999, levied tax at the rate of 10% on disputed turnover, in the absence of certificates in Form “D”. 12. It is to be noted here that the Deputy Commissioner, in the order, dated 24.02.1999, levied tax at the rate of 10% on disputed turnover, in the absence of certificates in Form “D”. Therefore, the argument of the learned counsel for the petitioner that the authorities failed to consider the certificates in Form “D” cannot be accepted. Further, learned counsel for the petitioner submits that the certificates in Form “D” were filed before the Tribunal but the same were also not considered. 13. It is to be noted here that the certificates in Form “D” are to be filed before the authorities concerned and not before the Tribunal. Filing of the same before the Tribunal, in our view, may not serve any purpose. 14. Accordingly, all these Tax Revision Cases are dismissed. There shall be no order as to costs. Miscellaneous petitions pending, if any, in these Tax Revision Cases shall stand closed.