R. V. RAVEENDRAN, J. ( 1 ) ISSUE rule. Statement of objections already filed. The matter is heard finally by consent. ( 2 ) THE petitioner is a dealer in mild steel flanges, registered under the Karnataka Sales Tax Act, 1957 (for short, "the Act" ). The petitioner claims that M. S. flanges falls under entry 2 (a) (xi) of the Fourth Schedule subject to sales tax at 4 per cent as declared goods in respect of which single point tax is leviable. Assessments have also been completed for the years 1994-1995, 1995-1996, 1996-1997, 1997-1998, and 1998-1999, as per the orders of assessment passed on November 16, 1995, April 2, 1997, January 7, 1998, July 2, 1999 and February 15, 2000 subjecting M. S. flanges to tax at 4 per cent under entry 2 (a) (xi) of the Fourth Schedule read with Section 5 (4) of the Act. ( 3 ) WHEN the matters stood thus, the Assistant Commissioner of Commercial Taxes, Cross verification III, South Zone, Bangalore (second respondent) inspected the business premises of the petitioner on August 6, 1999 and issued a notice dated December 20, 2000 under Section 29 (1) (e) and 29 (2) (e) read with Section 28 (1) and Section 31 of the Act alleging that the mild steel flanges traded by the petitioner cannot be classified under entry 2 (a) (xi) of the Fourth schedule and that they are exigible for tax under entry 6 of Part "p" in Second Schedule at the rate of 8 per cent up to March 31, 1998 and at the rate of 10 per cent from April 1, 1998. The petitioner filed objections dated January 15, 2001 contending that M. S. flanges fell under entry 2 (a) (xi) of the Fourth Schedule and therefore they could not be subjected to tax under entry 6 of part "p" of the Second Schedule. The petitioner filed objections dated January 15, 2001 contending that M. S. flanges fell under entry 2 (a) (xi) of the Fourth Schedule and therefore they could not be subjected to tax under entry 6 of part "p" of the Second Schedule. ( 4 ) ON the basis of a reference made by the second respondent, the assessing authority (third respondent) has issued five notices dated February 5, 2001 (annexures A to E) under Section 12-A of the Act alleging that there was mistake apparent on the face of record by subjecting m. S. flanges to tax under entry 2 (a) (xi) of the Fourth Schedule and proposing to rectify such mistake by subjecting the sale of mild steel flanges to tax under entry 6 of Part P of the Second schedule. ( 5 ) FEELING aggrieved, the petitioner has filed these petitions and sought quashing of annexures "a" to "e". The petitioner has also sought a direction to the first respondent not to apply or enforce the rate of tax under entry 6 of Part "p" of the Second Schedule in regard to mild steel flanges dealt by it. The petitioner has also sought a declaration that the mild steel flanges are taxable only under Section 5 (4) read with entry 2 (a) (xi) of the Fourth Schedule. ( 6 ) THE respondents do not dispute that what is dealt with by the petitioner are mild steel flanges. In fact, in para 2 of the impugned notices issued under Section 12-A and in para 7 of the statement of objections, the respondents have clearly admitted that what is dealt with by the petitioner are mild steel flanges. ( 7 ) THE dictionary meaning of a "flange" is a projecting edge, rim or flank added for strength or for connecting with another object or part. The Indian Standard Specification for steel pipe flanges discloses that flanges can be of different types, that is integral, welding neck, plate, screwed boss, slip-on boss, loose or blank for use in steel pipes for carrying oil, water, steam, air, gas and chemicals. They can be forged cast, plate or flat. ( 8 ) THE relevant entries are extracted below : entry 2 (a) (xi) of the Fourth Schedule : " (a) Iron and steel, that is to say. . . . . . . . . . . They can be forged cast, plate or flat. ( 8 ) THE relevant entries are extracted below : entry 2 (a) (xi) of the Fourth Schedule : " (a) Iron and steel, that is to say. . . . . . . . . . . (xi) Steel tubes, both welded 4% (from 15-7-1975)" and seamless, of all diameters and lengths, including tube fittings. Entry 6 of Part 'p' of the Second Schedule : "pipes, tubes and fittings of iron 8% (1-4-1996 to 31-3-1998) (not falling under Schedule IV) 10% (from 1-4-1998 ). " cement, stoneware and asbestos cement grills, pitch fibre pipe. ( 9 ) ACCORDING to the department, mild steel flanges are ready to use industrial components made out of M. S. flats according to specifications given by customers ; that they are circular plates of different diameter made out of M. S. flats containing holes of different types ; and that therefore, m. S. flanges are component parts for industrial and other purposes. ( 10 ) BUT, the question is not whether the mild steel flanges are component parts for industrial and other purposes, but whether they fall under entry 2 (a) (xi) of the Fourth Schedule as contended by petitioner or under entry 6 of Part P of the Second Schedule. Admittedly, mild steel flanges are not pipes, tubes nor fittings of iron nor are they cement or stonewares or asbestos. Only if the flange is an iron fitting for a pipe or tube, it may fall under entry 6 of Part P of the Second schedule, that too if does not fall under the Fourth Schedule. If M. S. flanges are fittings for steel tubes (both welded and seamless) it will fall under entry 2 (a) (xi) of the Fourth Schedule. But as rightly pointed out by the learned Additional Government Advocate, a flange need not necessarily always be a fitting for a tube. It is a projecting rim added for strength or for connecting with another object or part. Therefore, whether a mild steel flange falls under entry 2 (a) (xi) of the Fourth Schedule or not will depend on the fact whether it is intended to be used as a fitting for steel tube or for something else. Rut, if it is not an "iron filling" it may not fall under entry 6 of Part P of the Second Schedule. Rut, if it is not an "iron filling" it may not fall under entry 6 of Part P of the Second Schedule. This factual aspect has to be examined by the assessing authority. ( 11 ) THE assessing authority should also keep in view the fact that ever since the introduction of entry 2 (a) (xi) in the Fourth Schedule with effect from July 15, 1975, mild steel flanges have been taxed at 4 per cent under the said entry and is also the subject-matter of Commissioner's clarification No. 449/89-90 dated November 2, 1989. It is true that all clarifications issued up to may 28, 1996 have been withdrawn prospectively as per circular dated February 26, 1997. But, nevertheless, as observed by a division Bench of this Court in Subhash Marketing v. Commissioner of Commercial Taxes in Karnataka [2000] 118 STC 136 any clarification in favour of the assessee cannot be ignored, for assessments, during the period when such clarification was in effect. Be that as it may. ( 12 ) IN view of the above, these petitions are allowed in part and annex-arcs A to E dated february 5, 2001 proposing to tax M. S. flanges under entry 6 of Part P of the Second Schedule are quashed. This will not come in the way of the assessing authority sending fresh proposition notices, if he finds that mild steel flanges are required to be taxed under some other entry.