(1.) Having regard to the categorical finding of the Sales Tax Appellate Tribunal that there is no provision in the contract contemplating transfer of ownership or possession of the equipment belonging to the respondent Company to Oil and Natural Gas Commission (ONGC), we are of the view that no question of law falling within the ambit of Section 22 of the Andhra Pradesh General Sales tax Act arise for consideration by this Court in this TRC and the same is, therefore, dismissed at the admission stage.