PRAKASH KRISHNA, J. ( 1 ) ALL the aforementioned six revisions, filed at the instance of Commissioner of Trade Tax, were heard together and are being disposed of by a common judgment as a common question is involved in all of them. In all these revisions the question involved is regarding the taxability of automatic voltage stabilizer. According to the assessees the automatic voltage stabilizer should be taxed as electronic goods as defined in Notification No. 1223 dated March 31, 1992 and the notification No. 3402 dated October 1, 1994. The case of the department is that voltage stabilizers are liable to be taxed as electrical goods. ( 2 ) THE dealers opposite-parties carried on the business of manufacture and sale of voltage stabilizers. The only difference is that in Trade References Nos. 4 and 5 of 1999 the assessing officer did not accept the case of the assessee that the voltage stabilizers are liable to be taxed as electronic goods. In rest of the revisions, i. e. , Trade Tax References Nos. 269, 272, 273 and 274 of 2000 the assessing officer had accepted the claim of the dealer that voltage stabilizers are liable to tax as electronic goods, but the said order was set aside in revision under Section 10-B of the U. P. Trade Tax Act, 1948. In all these matters the Tribunal has held that voltage stabilizers are electronic goods. ( 3 ) HEARD the learned Standing Counsel for the applicant and Sri Bharatji Agrawal for the opposite-parties. ( 4 ) THE entry 74 of Notification No. 1223 dated March 31, 1992 reads as follows : "74 (a) Electronic goods made by such tiny units whose investment in plant, machinery, equipment and apparatus as certified by Chartered Accountant, does not exceed five lakh rupees and which manufactures and sells electronic goods notified by Development Commissioner, small Scale Industries, Government of India. (b) Consumer electronic goods that is to say black and white television, tape recorders, and public address system. (c) Office equipment that is to say data processing system, micro processor based mini/micro computer system, computer peripherals, dot matrix printers, line printers, desk top publishing system, floppy drives, hard disk drives, video display terminals, key boards, mouse, plotters, digitizers, monitor, cartridge tape, steamer drive, calculators, electronic typewriters, data entry machines, automatic teller machines, cash dispensers. (d) Photo copiers. (c) Office equipment that is to say data processing system, micro processor based mini/micro computer system, computer peripherals, dot matrix printers, line printers, desk top publishing system, floppy drives, hard disk drives, video display terminals, key boards, mouse, plotters, digitizers, monitor, cartridge tape, steamer drive, calculators, electronic typewriters, data entry machines, automatic teller machines, cash dispensers. (d) Photo copiers. (e) Electronic components, that is to say, all types of passive components/resistors, capacitors, diodes and other active components, transistors, integrated circuits, large scale integration/very large scale integration chips, black and white picture tubes, colour picture tubes, power semi-conductors, audio tapes and video tapes, printed circuit boards/connectors, relays, upto electronic components, precision electronic components, magnetic media, microwave tube, television components, television glass shell, electronic transducers, actuators, display devices that is light emitting diodes/liquid crystal diodes, micro meters for video cassette recorders/video cassette players, crystals, tape deck mechanism, etched and framed foils, electronic tuners, deflection yokes, line out put transformers, electro deposited copper foils, printed circuit board laminate, populated printed circuit boards, power supply devices, cabinet. (f) All other electronic goods, parts and accessories not covered in any of the aforementioned categories. " The aforequoted notification was subsequently amended by another Notification No. 3402 dated october 1, 1994. The rate of tax was changed but the entry for the purposes of the present cases continues to be the same. The relevant entry for the present purposes is entry No. 74 (f) of the notification. The rate of tax by the subsequent notification was reduced from eight per cent to four per cent and the relevant entry is 74 (a) (iii ). The said entry provides that all other electronic goods not specified anywhere else in the Schedule or in any other notification shall be liable to be taxed at the rate of 4 per cent as manufacturer or importer. Interpreting the above notifications, it was submitted that voltage stabilizer is nothing but an electrical goods and is not covered by any of the items mentioned in the aforesaid two notifications. Reliance was placed upon an order passed by the Commissioner, Trade Tax, under Section 35 of the said Act. Interpreting the above notifications, it was submitted that voltage stabilizer is nothing but an electrical goods and is not covered by any of the items mentioned in the aforesaid two notifications. Reliance was placed upon an order passed by the Commissioner, Trade Tax, under Section 35 of the said Act. The learned Standing Counsel on the basis of two judgments reported in [1996] 100 STC 557 (Mad.) (Standard Appliances v. State of Tamil Nadu) and [1992] 84 STC 266 (AP) (State of Andhra pradesh v. Kaka Enterprises) submitted that voltage stabilizers are taxable as electrical goods. The argument of the learned Standing Counsel is misplaced. In the aforesaid judgments the court was considering the question as to whether voltage stabilizers could be accessories to the refrigerators or television sets. It was held that the voltage stabilizers cannot be termed as accessories to the refrigerators and television sets as they are also used with other electrical goods. In that connection it was held that voltage stabilizers are not accessories of television sets or refrigerators and are liable to be taxed as electrical goods. In the aforesaid cases the controversy as to whether the voltage stabilizers should be taxed as electrical goods or as electronic goods was not involved. Therefore, the aforesaid cases are distinguishable on facts. ( 5 ) SRI Bharatji Agrawal has placed reliance upon a circular dated June 6, 1992, issued by the commissioner, Sales Tax, in relation to the notification dated March 31, 1992 with respect to entry 74 (a ). In the said circular a list of electronic goods, with the consultation of Development commissioner, Small Scale Industries, Government of India, has been issued, which contains the names of products as electronic goods. At Sl. No. 60 solid state voltage stabilizers and at Sl. No. 79 servo control voltage stabilizers have been mentioned in the list of electronic goods. The said list has been issued with reference to entry 74 (a) of the notification under consideration. Entry 74 (a) provides for lesser rate of tax on electronic goods manufactured by tiny units whose investment in plant, machinery, equipments and apparatus does not exceed rupees five lakhs. Entry 74 (f) is in the nature of residuary entry. It covers all other electronic goods, parts, etc. , not covered by the other entries. Entry 74 (a) provides for lesser rate of tax on electronic goods manufactured by tiny units whose investment in plant, machinery, equipments and apparatus does not exceed rupees five lakhs. Entry 74 (f) is in the nature of residuary entry. It covers all other electronic goods, parts, etc. , not covered by the other entries. The opposite-parties are manufacturers of voltage stabilizers and have made investments exceeding rupees five lakhs in plant, machinery, etc. There is substance in the argument of the counsel for the opposite-parties that the voltage stabilizers have been treated as electronic goods if manufactured by tiny units. The same goods will not cease to be the voltage stabilizers if manufactured by other than tiny units and will continue to be electronic goods and will be covered by sub-entry (f) of entry 74, though chargeable at higher rate, The intention of the Department in issuing the circular dated June 6, 1992 is apparent to treat the items mentioned therein, including the voltage stabilizers as electronic goods. ( 6 ) IN [2001] 122 STC 100 (SC); 2000 UPTC 472 (Commissioner of Sales Tax v. Indra industries) it was held by the honourable Supreme Court that the circular issued by the commissioner is binding upon the department. The departmental authorities cannot be permitted to contend that the circular issued by the Commissioner is contrary to law. The Tribunal has also placed reliance upon certificate issued by the Principal Director of Electronic Services and training Centre, which is a Government of India undertaking, certifying that automatic voltage stabilizers are electronic goods. The Tribunal has further reliance on Prime Minister Rojgar yojna for self employment in electronic industries. The Tribunal has also placed reliance on certain other material and especially on a book of electronic engineering to hold that automatic voltage stabilizers are electronic goods. The learned Standing Counsel could not place any material before me to show that automatic voltage stabilizers have not been treated as electronic goods ; but as electrical goods. ( 7 ) I have perused the order passed by the Commissioner, Trade Tax, under Section 35 of the Act. There is absolutely no discussion in the said order of the Commissioner as to why the automatic voltage stabilizers shall be treated as electrical goods and not as electronic goods. ( 7 ) I have perused the order passed by the Commissioner, Trade Tax, under Section 35 of the Act. There is absolutely no discussion in the said order of the Commissioner as to why the automatic voltage stabilizers shall be treated as electrical goods and not as electronic goods. ( 8 ) FOR the reasons given above and especially in view of the circular issued by the Commissioner of Trade Tax under entry No. 74 (a) including the voltage stabilizers in the list of electronic goods manufactured by tiny units, I hold that the voltage stabilizers manufactured otherwise than by tiny units shall also be electronic goods and the Tribunal has committed no illegality in holding them as such. ( 9 ) IN view of the above, all the revisions are dismissed. .