Judgment :- DR. A. S. ANAND, C.J. The controversy in this tax appeal filed by the assessee is limited only to the turnover of Rs. 1, 95, 497.75 relating to the first sale of oil 666. The assessing authority taxed the turnover relating to oil 666 at 8 per cent. single point treating the commodity to be covered under item 47 of the First Schedule. On appeal, the Appellant Assistant Commissioner held oil 666 to be taxable at 4 per cent. multi-point and allowed the appeal. The Joint Commissioner proposed to revise the order of the Appellate Assistant Commissioner in exercise of the suo motu power of revision. Consequently, a notice was issued to the assessee and after inviting its objection and hearing the parties, the Joint Commissioner confirmed the proposal and setting aside the order of the Appellate Assistant Commissioner, restored that of the assessing authority. The assessee is in appeal before us. 2. Learned counsel for the appellant submitted that in view of the clarification which had been issued by the erstwhile Board of Revenue on March 6, 1972, relating to oil XB 999 and XB 700, the oil which is the subject-matter of dispute in the present case was also liable only to tax at multi-point rate. This plea had been raised before the Joint Commissioner also. The Joint Commissioner found that the Board's earlier clarification dated March 6, 1972, is relating to different oils and had no relevance to the facts of the case on hand. The Joint Commissioner rightly opined that the rate of tax applicable to each product has to be decided with reference to the facts of that product. The Joint Commissioner noticed that with regard to the correct rate of tax so far as oil 666 is concerned, the Commissioner of Commercial Taxes had issued a clarification in his administrative capacity that oil 666 processed and sold as lubricating oil was taxable at 8 per cent. single point under item 47 of the First Schedule to the Tamil Nadu General Sale Tax Act, 1959 during the relevant period. Even without that clarification we find that what was sold by the appellant-assessee was only processed lubricating oil. single point under item 47 of the First Schedule to the Tamil Nadu General Sale Tax Act, 1959 during the relevant period. Even without that clarification we find that what was sold by the appellant-assessee was only processed lubricating oil. Keeping in view the process of manufacture, its physical and chemical properties, its application and use and the manner in which the oil is understood in common parlance and by the trade in general, the view of the Joint Commissioner that oil 666 was nothing but lubricating oil and covered by entry 47 of the First Schedule to the Act is wholly justified. The Appellate Assistant Commissioner clearly fell in error in treating oil 666 as taxable at 4 per cent. multi-point without considering the physical and chemical properties of the oil and also as to how it is understood in common parlance and by the trade in general. Entry 47 of the First Schedule at the relevant time read "lubricating oils and greases" and from August 15, 1974, the rate of tax was 8 per cent. at the point of first sale in the State. Since oil 666 is a lubricating oil, it is covered by the entry at it existed at the relevant time and the Joint Commercial rightly found so. No error is therefore found in the order of the Joint Commissioner which is based on proper appreciation of the materials on record and correct application of the entry in the First Schedule. The tax appeal, therefore, fails and is dismissed. No costs.