Judgment :- GOVINDAN NAIR, C.J. The short question raised is whether the fountain-pen nibs would fall under items 109 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959. The item read as follows : "Articles made of stainless steel." The Tribunal has held that fountain-pen nibs cannot be treated as an article made of stainless steel. We are inclined to agree. When one speaks of an article made of stainless steel, it is essential that the article must at least be substantially made of stainless steel. Counsel for the revenue took the example of stainless steel vessel made of stainless steel with a wooden handle and posed the question whether such a vessel with the handle could not be treated as an article made of stainless steel. Perhaps such an article could be said to be made of stainless steel, though the handle part of it was made of wood. This is so because the article with the handle is still substantially made of stainless steel. But the same, we do not think, can be said of a fountain-pen nib. The trip of nib can be either platinum or some other valuable substance. In this case, iridium has been used and it is the most important part of the nib and without it the nib becomes useless or becomes of much less use as the nib of a fountain-pen. In fact, as we said, the iridium part of it is the most important part and the value of it must be much more than the value of the steel that has been used in the nib. In any view of the matter, it is impossible to say that the fountain-pen nib is substantially made of stainless steel. Such articles we do not think would fall under item 109 of the First Schedule. We, therefore, dismiss this tax revision case.