JUDGMENT K. Narayana Kurup, J. 1. This appeal at the instance of the State is directed against the order of the Sales Tax Appellate Tribunal, Addl. Bench, Palakkad in T.A. No. 241191 dt. 30.1 1.1998 allowing the appeal filed by the assessee and directing the assessing authority to amend the assessment for the year 1985-86 treating 'Cage Wheel' as an agricultural implement coming under Entry 4 of the I Schedule of the Kerala Central Sales Tax Act (for short 'the Act') as against the contention of the State that 'Cage Wheel' is a spare part or component of the tractor coming under Entry 138 of the Act as it then stood. 2. In the original assessment for the year 1985-86 sale of 'cage wheels' was subjected to tax at the rate of 6% treating it as all agricultural implement coming Entry 4 of the 1st schedule of the Act. Subsequently, the assessing authority found that 'cage wheel' is a part of tractor liable to be assessed at the rate of 10% under Entry 138 of the I schedule of the Act. The assessment was revised accordingly, levying tax at the rate of 10% for the sale of cage wheel. On appeal the Appellate Asst. Commissioner confirmed the order of the assessing authority and found that cage wheel is a part of tractor. Aggrieved thereby, the assessee moved the Appellate Tribunal in appeal. The bone of contention between the parties is whether 'cage wheel' is an agricultural implement coming under Entry 4 of Ist schedule of the Act or an accessory or component of a tractor coming under Entry 138 of the Ist Schedule of the Act. According to the assessee, 'cage wheel' is an agricultural implement and that it is not a spare part of tractor and hence 'cage wheel' is not liable to be assessed at the rate of 10%. On a plain reading of Entries 4 and 138 of 1st schedule of the Act we find that the contention of the assessee is well founded. Entries 4 and 138 are extracted below: "Entry 4: Agricultural machinery and implements not falling under any other entry in this Schedule other than hand made. Entry 138: Motor Vehicles, motor vessels, motor engines, chassis of motor vehicles, trailors, motor bodies built on the chassis of motor vehicles, bodies built for motor vessels or engines and spare parts and accessories thereof". Entry 138: Motor Vehicles, motor vessels, motor engines, chassis of motor vehicles, trailors, motor bodies built on the chassis of motor vehicles, bodies built for motor vessels or engines and spare parts and accessories thereof". Entry 138 is attracted only in the case of all engine or a spare part or an accessory of a trailor. Evidently 'Cage wheel' will not come under any of the aforesaid categories, it is neither an engine nor a spare part nor an accessory of a trailor. When a tractor is purchased 'cage wheel' is not attracted to i. In fact, tractors are sold in the market without 'cage wheel'. So, the reasoning of the Tribunal that 'cage wheel' is not an essential part of tractor, since tractor can work without 'cage wheel' is unsustainable. In support of its findings, the Tribunal has relied on the decision of the Supreme Court in (1977) 30 STC 8 (State of Uttar Pradesh v. Kores (India) Ltd.) wherein it has been held that ribbon is an accessory of the typewriter and not a part of the typewriter, though it may not be possible to type out any matter without it. Here, the case is stronger for the assessee in so far as a tractor can be operated even without a 'cage wheel' which therefore, cannot be treated as an accessory of the former. 'Cage wheel' will be used only in the event of the tractor being put to use for ploughing and levelling the land. In that sense, 'cage wheel' cannot be treated as an essential part of tractor at all. At any rate, it cannot be treated as an engine or a spare part or an accessory attracting Entry 138 of Ist Schedule to the Act. The approach more in conformity with common sense, will be to treat 'cage wheel' as an agricultural implement coining under Entry 4 of Ist Schedule of the Act. Since 'cage wheel' is used in connection with agricultural purpose, viz. for ploughing and levelling the land, the Tribunal rightly treated as an agricultural implement attracting Entry 4 as already noted. The approach more in conformity with common sense, will be to treat 'cage wheel' as an agricultural implement coining under Entry 4 of Ist Schedule of the Act. Since 'cage wheel' is used in connection with agricultural purpose, viz. for ploughing and levelling the land, the Tribunal rightly treated as an agricultural implement attracting Entry 4 as already noted. In the aforesaid view, we hold that 'cage wheel' cannot be treated as part of tractor or its engine or spare part or accessory and as a sequel the turn over of 'cage wheel' would not be subjected to sales tax at the rate of 10% and it will be liable to tax only at the rate of 6%. The order of the Tribunal treating 'cage wheel'' as an agricultural implement and liable to be taxed only at the rate of 6% under Entry 4 Ist schedule of the Act cannot be set aside on any of, the grounds mentioned in the memorandum of T.R.C. In the result, we confirm the order of the Tribunal and dismiss this T.R.C.