JUDGMENT B. P. JEEVAN REDDY, C.J. - These two revisions are preferred by the Commissioner of Sales Tax, U.P., against a common order of the Sales Tax Tribunal, Lucknow Bench, in two second appeals. The concerned assessment years are 1971-72 and 1972-73. The question at issue is whether trailers concerned herein are accessories to jeeps or not. It was agreed before the assessing and appellate authorities that if it is an accessory of jeep, it would be taxable at the rate of 10 per cent as per Notification No. ST/1921/X-905(1)-64 dated May 1, 1968 whereby item 10 of the notification dated June 1, 1963 was substituted. The assessing authority held that the trailers in question having been manufactured for the purpose of being used as trailers to jeeps, constitute accessories and are, therefore, taxable at the rate of 10 per cent. On the other hand both the appellate authorities have taken the view, mainly influenced by the clarification issued by the Commissioner in ST-2-3642/X-79-6(11)/79 dated June 18, 1979 that the trailers cannot be treated as accessories to jeeps. The appellate authorities held that they are taxable as unclassified item. The relevant entry in Notification No. 1563 and which entry is admittedly applicable to the two assessment years concerned herein is as follows : "Motor tyres and tubes, spare parts and component parts of motor vehicles, not being such parts as are ordinarily also used for purposes other than as parts of motor vehicles and articles adapted for use as accessories of motor vehicles, motor cars, motor taxi-cabs, motor cycles and motor cycle combinations, motor scooters and motorettes, motor omnibus, motor vans and motor lorries." In fact, the said item is in two parts, namely, (1) motor tyres and tubes, spare parts and component parts of motor vehicles, not being such parts as are ordinarily also used for purposes other than as parts of motor vehicles and (2) articles adapted for use as accessories of motor vehicles, motor cars, etc. This is how all the authorities under the Act have understood the item and I see no reason to take a different view. It is on this basis that the question arose whether the trailers in question constitute accessories to motor vehicles. This in turn raises the question what is the meaning of accessory or accessories as the case may be. It is on this basis that the question arose whether the trailers in question constitute accessories to motor vehicles. This in turn raises the question what is the meaning of accessory or accessories as the case may be. In [1976] 37 STC 378 (SC); AIR 1976 SC 1418 (Annapurna Carbon Industries Co. v. State of Andhra Pradesh), the said aspect has been dealt with elaborately. The entry concerned therein was entry No. 4 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 which runs as follows : "Cinematographic equipment including cameras, projectors, and sound recording and reproducing equipment, lenses, films and parts and accessories required for use therewith." The question was whether the are carbons known as "cinema are carbons" fell within the said entry. The Supreme Court pointed out that the entry uses both the expressions, "parts" and "accessories" and then proceeded to ascertain the meaning of the word "accessory". The following two paragraphs are instructive : "We find that the term 'accessories' is used in the Schedule to describe goods which may have been manufactured for use as an aid or addition. A sense in which the word 'accessory' is used is given in Webster's Third New International Dictionary as follows, 'an object or device that is not essential in itself but that adds to the beauty, convenience, or effectiveness of something else.' Other meanings given there are. 'Supplementary or secondary to something of greater or primary importance', 'additional', 'any of several mechanical devices that assist in operating or controlling the tone resources of an organ'. 'Accessories' are not necessarily confined to particular machines for which they may serve as aids. The same item may be an accessory of more than one kind of instrument. It will be noticed that the entry we have to interpret includes 'parts' as well as 'accessories' which are required for use in projectors or other cinematographic equipment. We think that the Andhra Pradesh High Court correctly held that the main use of the arc carbons under consideration was duly proved to be that of production of powerful light used in projectors in cinemas. The fact that they can also be used for searchlights, signaling, stage lighting, or where powerful lighting for photography or other purposes may be required, could not detract from the classification to which the carbon arcs belong. The fact that they can also be used for searchlights, signaling, stage lighting, or where powerful lighting for photography or other purposes may be required, could not detract from the classification to which the carbon arcs belong. That is determined by their ordinary or commonly known purpose or user. This, as already observed by us, is evident from the fact that they are known as 'cinema are carbons' in the market. This finding was enough, in our opinion, to justify the view taken by the Andhra Pradesh High Court that the goods under consideration are covered by the relevant entry No. 4." The meaning attached to the word "accessories" in this decision has been followed later by another decision of the Supreme Court in [1991] 80 STC 233 (SC); AIR 1991 SC 1017 (Mehra Bros. v. Joint Commercial Tax Officer). A perusal of paragraph 10 of the decision of the Supreme Court first mentioned would show that the word "accessory" has a very wide meaning or rather it has several meanings. The appropriate meaning has to be chosen by the court having regard to the context in which the expression occurs. As in the case before the Supreme Court, here too, the entry in question employs both the expressions, parts and accessories. It is worth mentioning that the main entry relates to motor tyres and tubes, spare parts and component parts. The second limb of the entry brings in articles adapted for use as accessories to motor vehicles. The question, therefore, arises which is the appropriate meaning to be attached having regard to the context. The learned Standing Counsel contends vehemently that an object or device that adds to the effectiveness is an accessory. He also says that an object which is supplementary or secondary to something of greater or primary importance is also an accessory. For this reason, he has contended that trailer in question must be treated as accessory to jeeps. I do not say that there is no force in this contention but in my opinion, it is not necessary for me to express any definite opinion on this question since I am of the view that the revision must fail in view of the circular issued by the Commissioner on June 18, 1979 with respect to the assessment years in question and which has been relied upon by the appellate authorities. The circular in question reads thus : * * * Extract from File No. 6(11)/79 : "It would be difficult to sustain the argument that the trailer is an accessory to the jeep. The reason is that for its normal functioning the jeep does not require the aid of the trailer. The trailer is something by way of an addition or supplemental to the jeep designed with the object to add to its ordinary loading capacity and the jeep can work even independently without there being trailer attached to it. 2. The revision in the matter may not, therefore, be said to be likely to succeed. Sd/- B. D. Agarwal D.L.R. 30-5-1979." A reading of this circular shows that the Government itself had entertained a doubt as to the proper item under which the trailer ought to be taxed and accordingly obtained the opinion of the Law Department. The Law Department opined that the trailer is not an accessory to the jeep. That opinion was communicated to the Commissioner which in turn the Commissioner communicated to all the Sales Tax Officers. Another circumstance to be noticed is that the said opinion was obtained and rendered with reference to the assessment years 1970-71 to 1972-73. I would be justified in presuming that this circular must have been followed by the various assessing authorities in the State. The very fact that the said circular has been made the basis of their decision by both the appellate authorities shows that much importance has been attached by them to this circular. If so, there is no reason why a different treatment should be meted out to the assessee herein. The learned Standing Counsel contended that the said circular is not statutory in character and that it cannot bind the assessing authorities while making assessment. He submits that the assessment has to be made in accordance with law and that the said circular not being statutory does not bind the assessing authorities. May be so, but it would be idle to contend that the said circular was issued with no specific purpose. It was intended to bring in uniformity of treatment and to avoid different assessing authorities taking different views. It is also not brought to my notice that the said circular has since been withdrawn. May be so, but it would be idle to contend that the said circular was issued with no specific purpose. It was intended to bring in uniformity of treatment and to avoid different assessing authorities taking different views. It is also not brought to my notice that the said circular has since been withdrawn. The learned Standing Counsel further contended that the very fact that the Commissioner himself has challenged the said view by filing these revisions shows that he does not adhere to the view expressed in the said circular. If the Commissioner has changed his mind as is contended by the learned Standing Counsel, one would have expected him to withdraw the said circular. He did not. In the circumstances, I see no reason to interfere with the judgment of the Tribunal which applied and followed the said circular and gave its benefit to the assessee herein. Sitting in revision, I cannot say that the Tribunal - or for that matter the first appellate authority-was not justified in following the said circular. For this reason, it is not necessary for me to go into the precise question regarding the meaning of the word "accessory" nor to go into the question whether, as a matter of law or fact, the trailer concerned herein are accessories of jeeps. Suffice it to say that in view of the circular aforesaid issued by the Commissioner which has been followed by both the appellate authorities, I am not inclined to interfere in these revisions. They accordingly fail and are dismissed. Petitions dismissed.