Judgment :- V. RAMASWAMI, J. In all these four cases the question for consideration whether the sale of imported tractor parts are liable to be taxed under Entry 55 of the First Schedule to the Tamil Nadu General ST Act, on single-point at the point of first sale in the State after import or whether the sales are liable for multi-point under the general provision contained in S. 3 of the Act. 2. The respondents in each of these cases imported these articles under import licences which authorised them to import agricultural tractor parts. The Costumes authorities also levied customs duty as for imports. The Customs authorities also levied customs duty as for import of agricultural tractor parts. But in most of the transactions the respondents-assessee have sold these articles as "spare parts for diesel engines". In some of the bills of some of the assessee they have charged 6 1/2 per cent sales-tax and in others they have charged only 2 1/2 per cent. 3. Before the AOs the assessees contended that they imported only agricultural tractor parts and the sale of agricultural tractor parts would not come under Entry 55 of the First Schedule to the Act. It was their contention that only tractor parts used for industrial tractors would come under the Entry and not the parts used for tractors used in agriculture. Both the AO and the Appellate Authority rejected this contention and held that item 55 of the First Schedule is general in terms and applied to all tractors, whether they are used for agricultural purposes or industrial purposes. 4. But the Tribunal took a different view on the ground that in the majority of cases they were sold as spare parts for diesel engines and that a manufacturer of similar product has shown a literature which described these as could be used as spare parts for diesel engines. On this ground the Tribunal held that the goods in question will not fall under item 55 of the First Schedule. 5. There is no evidence to show that the goods in question sold by the assessee could be used only as spare parts for diesel engines and not as spare parts for tractors. On this ground the Tribunal held that the goods in question will not fall under item 55 of the First Schedule. 5. There is no evidence to show that the goods in question sold by the assessee could be used only as spare parts for diesel engines and not as spare parts for tractors. On the other hand, the evidence showed that the import licence given to the assessee was only for import of spare parts for agricultural tractors and that they paid customs duty as for spare parts for agricultural tractors. In some of the bills also we find that these parts were sold as tractor parts for Ferguson Tractors. Even in the objections filed by the assessee they have stated that these goods, are used as spare parts for tractors. In view of this evidence, it could not be concluded that the goods in question could be used only as spare parts for diesel engines and not as spare parts for tractors. If the goods could be used as spare parts both for tractors and diesel engines, the question for consideration is whether the tax leviable comes under item 55 of the First Schedule or the general provision contained in S. 3. There could be no doubt that entries in the First Schedule being specific goods in respect of which a single-point levy is prescribed, though they might be goods which come under the description of goods in S. 3 they could be taxed only to single-point and not to multi-point under the general provision of S. 3 of the Act. Entry 55 of the First Schedule mentions all tractors and spare parts for those tractors as being liable for single point at the point of first sale in the State. The goods in question being parts of tractors, they will squarely come under Entry 55 of the First Schedule and would be liable to tax under that Entry. 6. The revision petitions are accordingly allowed and the orders of the Tribunal are set aside and the assessment orders are confirmed. The petitioner will be entitled to costs. Counsel's fee Rs. 150/- in each case.