ORDER S. R. NAYAK, J. In this tax revision case filed under section 22(1) of the Andhra Pradesh General Sales Tax Act, 1957 ("the Act", for short), it is stated that the following questions of law do arise for our decision : 1. The order of the Sales Tax Appellate Tribunal is improper and illegal. 2. The Sales Tax Appellate Tribunal failed to deal with the memorandum of grounds while disposing the appeal. Although those are the questions framed in the memorandum as questions of law, at the time of hearing, learned counsel for the petitioner would tell us that the following is the only question of law that arises for our consideration and decision : "Whether the Sales Tax Appellate Tribunal is justified in concluding that overhead and slide projectors fall under entry 4 of the First Schedule ?" This question arises in the following factual context : The petitioner is a registered dealer engaged in manufacture of defence instruments and optical components and for the assessment year 1982-83 it was assessed to tax on a net turnover of Rs. 3,55,741.22. Out of the said net turnover, an amount of Rs. 2,26,723.31 was the turnover relating to sales of overhead projectors which was subjected to tax at 4 per cent and an amount of Rs. 26,146.45 which was turnover regarding the sales of lenses was assessed to tax at 6 per cent treating overhead projectors as unclassified goods and the lenses as falling under entry 107 of the First Schedule of the Act. The Deputy Commissioner (CT), Punjagutta, on perusal of the assessment records came to the conclusion that overhead projectors representing a turnover of Rs. 2,26,723.31 are liable to be taxed at 12 per cent treating them as falling under entry 4 of the First Schedule and the lenses representing turnover of Rs. 26,146.45 also as falling under item 4 of the First Schedule and therefore, liable to be taxed at 12 per cent. He accordingly passed an order on August 30, 1990 subjecting the total turnover of Rs. 2,52,869.76 representing the sales of projectors and lenses of tax at 12 per cent treating the same as goods falling under entry 4 of the First Schedule and accordingly modified the orders of the assessing authority. He accordingly passed an order on August 30, 1990 subjecting the total turnover of Rs. 2,52,869.76 representing the sales of projectors and lenses of tax at 12 per cent treating the same as goods falling under entry 4 of the First Schedule and accordingly modified the orders of the assessing authority. Thereafter, the petitioner preferred an appeal before the Sales Tax Appellate Tribunal ("the Tribunal", for short) questioning the order passed by the Deputy Commissioner, Punjagutta, in exercise of his revisional powers under section 20(2) of the Act contending that the overhead projectors manufactured and sold by it cannot be considered as "Cinematographic equipment" under entry 4 of the First Schedule, that the said projectors sold by it have to be considered as general goods (unclassified goods) only and therefore, taxable only at 4 per cent during the relevant period as opined by the assessing authority; that similarly, the lenses sold by it fall only under entry 107 of the First Schedule taxable at 6 per cent during the relevant period and not under entry 4 of the First Schedule, and that the Deputy Commissioner was therefore not justified in revising the order of the assessing authority and subjecting both the goods to tax at 12 per cent treating them as goods falling under item 4 of the First Schedule. The Tribunal on a consideration of the above grounds urged before it and also referring to the leaflet published by the petitioner-company details of which are set out in para 3 of the order came to the conclusion that the view taken by the revisional authority that the overhead and slide projectors squarely fall under entry 4 of the First Schedule. In that view of the matter, the appeal filed by the petitioner herein was dismissed. The only contention of the learned counsel for the petitioner before us is that though according to the leaflet published by the petitioner-company the overhead and slide projector is shown to be "EPIL Mini 35 MM slide/film strip", the projector could be used to project only the still film strips and not motion film strips. We have carefully perused the order of the Tribunal and also the grounds of appeal. Nowhere this specific plea was taken before the Tribunal nor this plea was pressed into service at the time of arguments by the counsel for the petitioner before the Tribunal. We have carefully perused the order of the Tribunal and also the grounds of appeal. Nowhere this specific plea was taken before the Tribunal nor this plea was pressed into service at the time of arguments by the counsel for the petitioner before the Tribunal. It is trite to state that the question now urged before us is essentially a question of fact. Unless this factual question was addressed to the authorities and the Tribunal under the Act for their decision with the appropriate pleading, we are afraid such a plea could be permitted to be raised before us for the first time. It cannot be gainsaid that if an overhead projector could be used for projecting a film strip, thereby meaning, for projecting a still as well as motion film strip, certainly such a projector could be brought under entry 4 of First Schedule. In that view of the matter, we do not find any error in the order of the Tribunal and no question of law arises in this T.R.C. The T.R.C. is accordingly dismissed. No costs. Petition dismissed.