JUDGMENT The judgment of the Court was delivered by V. V. KAMAT, J. - This is one more proceeding where the Tribunal has proceeded to consider an aspect that does not arise anywhere either before the assessing authority or before the first appellate authority. The question that is taken up by the Tribunal as the main issue involved is that whether the tapioca chips purchased is liable to purchase tax. 2. We will demonstrate how the question does not even emerge from the position that is available from the two orders of the lower authorities. The assessee is a dealer, as described, in the purchase of tamarind seed to be converted into powder and sold in the name and style of M/s. Joseph Mathew & Sons at Market, Changanacherry. For the assessment year 1981-82 he produced the books of accounts in support of the return in form No. 8. There is absolutely no reference to the details of the transactions as to be found in the assessment order. In fact tapioca is not even mentioned. 3. Thereafter it is found that the accounts were found as not acceptable for certain reasons. With regard to the question under consideration it is only reason No. 6 that is relevant and it is as follows : "Purchase turnover of tapioca will be assessed to tax at the purchase point." The discussion is to be found in only one paragraph of four lines which is also as follows: "It is contended in the 6th para that tapioca is exempted from tax. This is not correct. Tapioca is exempted from April 1, 1983 only. Hence their contention is also overruled." Thus it is clear that the question of tapioca chips did not emerge on the factual matrix at the threshold in time. The question was only as to whether it is exempted from April 1, 1983 only and it that be so, as far as the assessment year in question (1981-82), there is no question of exemption. 4. Before the first appellate authority - the Appellate Assistant Commissioner of Agricultural Income-tax and Sales Tax, this is reproduced as one of the reasons for rejecting the accounts as reproduced hereinbefore with reference to the article tapioca simpliciter. 4. Before the first appellate authority - the Appellate Assistant Commissioner of Agricultural Income-tax and Sales Tax, this is reproduced as one of the reasons for rejecting the accounts as reproduced hereinbefore with reference to the article tapioca simpliciter. All that the appellate authority considered is to be found in the following paragraph : "The purchase turnover of tapioca is exempted from payment of tax under G.O. (Ms) No. 46/81/TD dated June 2, 1981. Therefore exemption will be allowed to the purchase turnover of tapioca with effect from June 2, 1981." This would show that for the assessment year in question (1981-82) tapioca was exempted. The question of chips was not at all urged and taken up for consideration. 5. It is then obvious that the Tribunal engaged itself in the consideration of a question which factually did not arise any time, either having been contended on behalf of the Revenue or even at the instance of the assessee. 6. Even then the Tribunal did not find any difference in regard to the article and it is on the basis of the natural position that the part necessarily follows the qualities of the whole and does not display any kind of difference in regard thereto. The Tribunal has observed that when timber is sown into planks, there is no change to the commodity, still it is timber. Proceeding further, the Tribunal has also thought that tapioca chips cannot be understood as separate from tapioca itself and if tapioca is raw, the chips made therefrom also shall assume the same character. Therefore, in spite of the position that the issue did not arise at all and has been taken up by the Tribunal on self-assumption that it is the main issue, it will not affect and disturb the original fabric that the question did not arise for consideration at all. For the above reasons the revision case stands dismissed. Petitions dismissed.