JUDGMENT The judgment of the Court was delivered by V. V. KAMAT, J. - The assessee has brought this revision case before this Court under section 41(1) of the Kerala General Sales Tax Act, 1963 alleging H that it is entry No. 141 and not 140A, then governing the situation with regard to the assessment year 1986-87 would apply in the context. 2. The assessee, M/s. Elgi Equipments Limited, is a company incorporated under the Companies Act, 1956 and is dealing in air compressors and other equipments meant for service stations. The assessee is on the files of the Assistant Commissioner (Assessment), Sales Tax Office, Special Circle-II, Ernakulam. As against the total turnover conceded at Rs. 60,62,155.35, the assessing authority fixed the turnover at Rs. 66,36,850. In the said process the assessing authority levied tax at 15 per cent in accordance with entry No. 140A as against 8 per cent in accordance with entry No. 141, with reference to the said turnover of car washer, greasing equipments, air compressors, elgi hydraulic lifts (garage servicing hoist). 3. Before the first appellate authority - Deputy Commissioner (Appeals), Agricultural Income-tax and Sales Tax, Ernakulam, it was urged that the term "lifts" specified in the entry signified lifts used for multi-storied buildings for convenience of the people or goods to different floors and the equipments used for raising motor vehicles to higher levels for convenience of service cannot be termed as lifts. The first appellate authority held that this contention does not hold good in view of entry No. 140A of Schedule I, specifically referring to lifts operated by electric hydraulic or any other mechanical power is taxable at 15 per cent. The said authority did not find any reason to interfere. 4. The Kerala Sales Tax Appellate Tribunal, Additional Bench, Ernakulam, considered the relevant group of entries which are as follows : "Transport equipments : 138 Motor vehicles, motor At the point of 15% vessels, motor engines, first sale in chassis of motor vehicles, the State by trailers, motor bodies built a dealer who on the chassis of motor is liable to vehicles, bodies built tax under on motor vessels section 5. or engines and spare parts and accessories thereof. 139 Motor cycles and motor do. 15% cycle combinations, motor scooters, mopeds and motorettes and spare parts and accessories thereof. 140 Boats (canoes, wooden do. 6% launches) 140A Lift operated by electric, do. or engines and spare parts and accessories thereof. 139 Motor cycles and motor do. 15% cycle combinations, motor scooters, mopeds and motorettes and spare parts and accessories thereof. 140 Boats (canoes, wooden do. 6% launches) 140A Lift operated by electric, do. 15% hydraulic or other mechanical power. 141 Machinery and transport do. 8% equipments (other than those specifically mentioned in the Schedule). 142 Bicycles, tandem cycles and do. 6%" cycle combinations and accessories and parts thereof. The Tribunal considered the group of entries as referring to transport equipments as the general heading given common to all in relation to the group of entries from 138 to 142. The Tribunal observed that the group of above entries should be understood to draw colour from the general heading, "Transport equipments" to understand the situation. The Tribunal relied upon the decision of this Court in Deputy Commissioner of Sales Tax (Law), Board of Revenue (Taxes), Ernakulam v. Padma Engineering Works [1990] 78 STC 49 wherein "taking colour from the context" was the principle applied to understand the meaning of the term "machinery" in the context of entry No. 141. The Tribunal also held that when entry No. 140A specifies its application to "lifts" in relation to the "transport equipments" there is no reason to understand entry No. 140A referring to elevators used in buildings and multi-storied structures. The Tribunal has observed that in the context of the situation, the term "lift" cannot be understood by resort to common parlance approach because of the special enactment with a group heading in the context. The Tribunal further held that in such a situation the proper approach is to understand the situation in the context of the functional text to understand lift as a machine for hoisting and in such a situation would have to be understood in the context of the situation relating to transport equipments. The Tribunal has observed that entry No. 140A is a specific entry in the context of the general sub-heading "transport equipments". In such a situation, the Tribunal held that the specific situation covered by an entry in the context would override the consideration for application of the general entry - entry No. 141. The Tribunal has observed that entry No. 140A is a specific entry in the context of the general sub-heading "transport equipments". In such a situation, the Tribunal held that the specific situation covered by an entry in the context would override the consideration for application of the general entry - entry No. 141. The Tribunal has observed that with reference to the two entries, one is of a general character and the other is of a special one attributable to the situations under consideration, the special entry will get preference in the matter of application to the special situation under consideration. 4A. Although the decision in [1990] 78 STC 49 [Deputy Commissioner of Sales Tax (Law), Board of Revenue (Taxes), Ernakulam v. Padma Engineering Works] was decided on October 6, 1986 and the entry for our consideration - entry No. 140A came on the statute book under the Kerala Finance Act, 1986 (No. 7 of 1986) with effect from April 1, 1986, having received the assent of the Governor on 30th July, 1986, this Court was concerned with entry No. 141 in isolation and in the context of the factual situation in regard to the article being vertical and horizontal hand saw and wood lathe, in a situation where the authorities below had taken the view that entry No. 141 would not govern the situation, the observation relating to the situation taking colour from the context are made and the said observations are relied upon by the Tribunal. We have seen the judgment and in regard thereto, the revenue lost in limine in regard to the contention that vertical and horizontal hand saw and wood lathe would not be taxable with reference to entry No. 141 treating it to be machinery having connection with the transport equipments. 5. In our judgment it cannot be said that the Sales Tax Tribunal decided erroneously the question of application of proper entry. Learned counsel contended with the help of the Fourth Schedule that came to be added by the Kerala Finance Act, 1987 (Act 18 of 1987) referring to item 8 thereof, "Fabrication and installation of cranes and hoists" that when the Act was amended with reference to the works contract involving transfer of goods, fabrication and installation of cranes and hoists are understood together. Learned counsel wanted to make use of this addition of Fourth Schedule. Learned counsel wanted to make use of this addition of Fourth Schedule. It is not possible to accept the submission with regard to the understanding of the legislative intention because the necessity for an attempt to understand the legislative intention would arise only when the concerned legislative language presents any kind of difficulty in regard thereto. We have already stated that entry No. 140A is more than clear in the context of the heading "transport equipments" and the other entries in regard thereto. The Tribunal has considered the entire situation and there is no need to run after finding out the legislative intention in regard thereto when the provision is abundantly clear. For all the above reasons tax revision case stands dismissed. Petition dismissed.