Judgment :- K. A. THANIKKACHALAM, J. The department is the petitioner herein. The assessment year involved in this revision is 1979-80. The assessee is a dealer in machinery parts made of stainless steel. For the year 1979-80, the assessee declared a taxable turnover of Rs. 16, 54, 040. The Deputy Commercial Tax Officer determined it at Rs. 16, 84, 827 of which a turnover of Rs. 12, 92, 391 was assessed to tax at the rate of 10 per cent. The assessing officer was of the view that this turnover relates to the entry under item 109 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959. 2. The Appellate Assistant Commissioner (Commercial Tax) on appeal confirmed the rate of taxes determined by the assessing officer. Aggrieved by the said order, the assessee filed an appeal before the Sales Tax Appellate Tribunal. The Tribunal held that the disputed turnover would relate to entry under item No. 81 of the First Schedule and not under item 109 of the First Schedule. Accordingly, the Tribunal held that the impugned turnover has to be assessed only at 6 per cent under item No. 81 of the First Schedule. Against the order of the Tribunal, this revision is filed by the department. 3. Learned Additional Government Pleader (Taxes) submitted that the Tribunal was not correct in holding the the disputed turnover relates to machinery mentioned under item 81 of the First Schedule. According to the learned Additional Government Pleader, the turnover relating to the spare parts sold by the assessee should be considered as articles made of stainless steel, falling under item 109 of the First Schedule prior to the amendment which came into effect from December 30, 1981. 4. It remains to be seen that the assessee manufactured boiler components made up of stainless steel according to the specifications given by the Bharath Heavy Electricals Limited, Trichy. The point for consideration is : "Whether the sale turnover of stainless steel components would fall under item 81 or 109 of the First Schedule prior to the amendment of the First Schedule ?" 5. The point for consideration is : "Whether the sale turnover of stainless steel components would fall under item 81 or 109 of the First Schedule prior to the amendment of the First Schedule ?" 5. Item 81 of the First Schedule reads as follows : " All machinery worked by (i) electricity, (ii) diesel, (iii) petrol, (iv) furnace oil, (v) Kerosene, (vi) coal including charcoal or (vii) any other fuel or power, and parts and accessories of such machinery other than those specifically mentioned in this Schedule." This item was amended with effect from September 30, 1977 by amendment Act 7 of 1977 in the following manner : "All machinery (other then those specifically mentioned in this Schedule) worked by (i) electricity, (ii) diesel or petrol, (iii) furnance oil, (iv) Kerosene, (v) coal including charcoal or (vi) any other form of fuel or power, and parts and accessories of such machinery and tools used with such machinery." * According to the assessee, the parts or accessories of machineries mentioned in item 81 of the First Schedule could have been made of any article. Originally item 109 of the First Schedule stated simply as articles made of stainless steel. The amendment is with effect from December 30, 1981 which stated as follows : "Articles made of stainless steel other than parts and accessories made of stainless steel falling under item 81 and the stainless steel nibs falling under item 109-A." 6. According to the learned counsel for the assessee, the amendment introduced to item 109 of the First Schedule though applicable from December 30, 1981, would go to show that even prior to the amendment what was excluded from entry 109 was spare parts and accessories made in stainless steel falling under item 81 of First Schedule. The main difference between entries 109 and 81 is all machineries made of whatever material would come under entry 81 and according to item 109 all machineries made of stainless steel would alone come under this entry for consideration. It remains to be seen that after amendment it was clarified that spare parts made of stainless steel would not fall under item 81 of the First Schedule. It is also well-established that articles which are falling under this special entry will not come under the general entry. It remains to be seen that after amendment it was clarified that spare parts made of stainless steel would not fall under item 81 of the First Schedule. It is also well-established that articles which are falling under this special entry will not come under the general entry. However, the Tribunal held that the parts and accessories of machinery made of any material especially stainless steel would fall only under item 81 as amended and cannot be brought under item 109, and the impugned turnover has to be assessed only at 6 per cent under item 81. It is also significant to note that there cannot be one rate for the machinery as a whole and another rate for its spare parts. Accordingly, we hold that the Tribunal was correct in levying tax at 6 per cent on the disputed turnover under item 81 of the First Schedule. In the result, the revision is dismissed. No costs.