7.The learned Government Counsel appearing on behalf of the respondents disputed the said contentions by stating that the petitioner-Institution is falling under the definition of “dealer” and more specifically, Section 2(15)(iii) enumerates that "a factor, a broker, a commission agent or arhati, a del credere agent or an auctioneer, or any other mercantile agent, by whatever name called, and whether of the same description as hereinbefore or not, who carries on the business of buying, selling, supplying or distributing goods on behalf of any principal, or through whom the goods are bought, sold, supplied or distributed". Therefore, the petitioner-Institution is also falling under the definition of “dealer”, as far as auctioning of the metal scraps, waste paper, empty bottles, plastic items, etc. When they are falling under the definition of “dealer”, as far as these items are concerned, the reference made regarding the order passed by the Tribunal is inapplicable with reference to the impugned orders passed now. The learned Government Counsel appearing on behalf of the respondents drawn a difference between the exemption granted as well as the Sales
