Judgment :- VENKATASWAMI, J. These two tax case appeals arise out of a common order of the erstwhile Board of Revenue made in B.P. Rt. No. 3912 of 1979 dated December 4, 1979. 2. The brief facts leading to the filing of these two tax case appeals are as follows : The appellant was allotted stainless steel sheets by the Director of Industries and Commerce for the purpose of manufacturing wind shield wiper arm blades for motor vehicles. From out of the stainless steel so allotted, the appellant manufactured stainless steel strips. The manufactured articles, viz., stainless steel strips were subsequently sold to Tvl. Tamarai Steel House. Initially, the sales of these stainless steel strips were assessed to tax at 8 per cent, for the two assessment years in question, namely, 1974-75 and 1975-76, treating them as falling under item 109 of the First Schedule to the Tamil Nadu General Sales Tax Act. Subsequently, on the basis of the report of the Intelligence wing, the assessments on this part of the turnovers were revised, and the turnovers were brought to tax at 13 per cent treating the goods as component parts of automobiles falling under item 3 of the First Schedule to the Act. 3. Aggrieved by the revised orders of the assessing authority, based on the Intelligence Wing's report, the appellant preferred two appeals to the Appellate Assistant Commissioner. The Appellate Assistant Commissioner, by his common order, found that what was sold by the assessee/appellant was only thin strip of metal from out of which a wiper can be made by an elaborate process after adding thereto other articles, and, therefore, it cannot be called a motor part. Consequently, the Appellate Assistant Commissioner held that the stainless steel strips sold by the assessee/appellant will fall only under item 109 of the First Schedule, and as such exigible to tax at 8 per cent. This common order of the Appellate Assistant Commissioner relating to assessment years 1974-75 and 1975-76 was scrutinised by the then Board of Revenue. The Board of Revenue was of the view that the Appellate Assistant Commissioner was not right in his conclusion. Therefore, notice was issued to the appellant requiring it to show cause as to why the stainless steel strips sold by it should not be treated as component of automobile and as such exigible to tax at 13 per cent. The Board of Revenue was of the view that the Appellate Assistant Commissioner was not right in his conclusion. Therefore, notice was issued to the appellant requiring it to show cause as to why the stainless steel strips sold by it should not be treated as component of automobile and as such exigible to tax at 13 per cent. The appellant submitted its objections. Overruling the objections, the Board of Revenue set aside the common order of the Appellate Assistant Commissioner and restored the revised order of the assessing officer. Aggrieved by the order of the Board of Revenue, the present appeals are filed by the assessee. 4. Mr. Venkataraman, learned counsel for the appellant, submitted that the Board of Revenue went wrong in holding that the articles sold by the appellant will fall under item 3 of the First Schedule to the Act, and as such exigible to tax at 13 per cent. According to the learned counsel, the Board of Revenue erred in taking into account the order of the allotment made by the Director of Industries. The stainless steel strips sold by the appellant cannot at all be used straightway as wiper blades to treat them as component part of the automobile. According to learned counsel, the view taken by the Appellate Assistant Commissioner and the reasons given by him in support of that view are unassailable, and the view taken by the Board of Revenue solely based on the allotment order cannot at all be sustained. 5. Mr. R. Karuppan, learned Additional Government Pleader, contending contra, submitted that the Board of Revenue is well within its jurisdiction in placing reliance on the allotment order of the Director of Industries. According to the learned Additional Government Pleader, the allotment was for the specific purpose of manufacturing the wind shield wiper arm blade and the invoices also clearly establish that what was sold was wind shield wiper arm blade, and, therefore, the Board of Revenue was right in treating the goods as component parts of automobiles. 6. We have carefully considered the rival submissions. It is seen from the orders of the Appellate Assistant Commissioner as well as the Board of Revenue that what was sold by the appellant was only thin strip of stainless steel metal and it cannot be straightway used as wiper blades. There is no dispute or controversy on this. 6. We have carefully considered the rival submissions. It is seen from the orders of the Appellate Assistant Commissioner as well as the Board of Revenue that what was sold by the appellant was only thin strip of stainless steel metal and it cannot be straightway used as wiper blades. There is no dispute or controversy on this. The Appellate Assistant Commissioner, in the course of his order, has stated as follows : "The Appellants presumably appear to have obtained quota for ever-silver sheets for manufacture of auto parts and the assessing authority appears to have been largely influenced by that circumstance in treating the strips as auto parts. For the purpose of taxation, the character of the article and not the basis on which raw materials allotment for manufacture is made is a criterion. Wipers are no doubt 'auto parts', but thin strip of metal from out of which a wiper can be made by an elaborate process after adding thereto other articles cannot be called a motor part. In the form in which it has been marketed, it cannot be sold as an auto part. It is only a part from which an auto part can be processed. Just as bolts and nuts which are used for the manufacture of a car cannot be treated as auto parts, this cannot be treated as auto part. The cost of each strip ranges at Re. 1.60 and Re. 1.80 each and wiper arm, as part of a motor vehicle can never be imagined to be sold at this low price. The observation in the case of Shadi Cycle Industries 1971 (27) STC 56 be sold at this low price. The observation in the case of Shadi Cycle Industries and Kishindas Agencies 1974 (1) LJ 149, 1974 (33) STC 65 , 1974 TaxLR 2150, 1974 (1) Kar(LJ) 149 (Mys) lend support to this view. I, therefore, hold that the stainless steel strips in question are not parts of motor vehicles, but only articles of stainless steel falling under item 109 of the First Schedule to the Act." * As against this, the view taken by the Board of Revenue is solely based on the allotment order of the Director of Industries. I, therefore, hold that the stainless steel strips in question are not parts of motor vehicles, but only articles of stainless steel falling under item 109 of the First Schedule to the Act." * As against this, the view taken by the Board of Revenue is solely based on the allotment order of the Director of Industries. The Board of Revenue, for reversing the order of the Appellate Assistant Commissioner, has stated as follows : "Taking into consideration the fact that the allotment of stainless steel sheets had been made by the Director of Industries for the specific purpose of manufacturing wind shield wiper arm blades and the facts that the assessee was a manufacturer of component parts of motor vehicles and the articles sold had been described in the bills as wind shield wiper arm blades, the assessing officer was quite correct in taking the goods at 13 per cent treating them as component parts of motor vehicles." * 7. The reliance placed by the Board of Revenue on a judgment of this Court reported in Khetty Traders v. State of Madras 1973 (32) STC 346 , is not at all apposite. As could be seen from the facts, the articles manufactured and sold by the appellant, by no stretch of imagination, can be treated as wiper blades, as something more has to be done to use it as wiper arm blade. That position was not disputed either before the authorities below or before us. If that be the correct position, we do not think that the Board of Revenue is right in treating the articles sold by the assessee as wiper arm blades coming under components of automobiles. On the other hand, the view taken by the Appellate Assistant Commissioner and the reasons given therefor appear to be quite in order. As rightly observed by the Appellate Assistant Commissioner, the stainless steel strip sold by the appellant is only a part from which an auto part can be processed. It is also relevant to note that the cost of the strip was only Rs. 1.60 or Rs. 1.80. No wiper arm as part of motor vehicle can be purchased for that price. 8. Accordingly, we set aside the order of the Board of Revenue and restore the order of the Appellate Assistant Commissioner. The appeals are allowed. However, there will be no order as to costs.