Judgment :- Radhakrishnan, J. These Tax Revision Cases have been preferred by the state of Kerala raising the following questions of law, which are extracted hereunder: (i) Is not the Tribunal in error in its conclusion that steel springs sold by the assessee would fall under Entry 2 (ii) (d) and 2 (ii) (f) of the second schedule to the Kerala General Salestax Act? (ii) Is not on a proper interpretation of the classification of the entries for the purpose of taxation under the Kerala General Salestax Act, steel springs would fall only under Entry 99/68 of the 1st schedule to the KGST Act? The assessee is a dealer in various types of steel sections, channels, bottom plates and wire coil (springs) mainly used for rolling steer bars. Assessment years in question are from 1991-1992 to 1996-1997. Primary question that has come up for consideration in these cases is whether steel spring sold by the assessee would fall under entry 99 of the First Schedule for the year 1991-92 which was taxable at 6% and for the year 1991-92 which was taxable at 6% and for year1992-93 and onwards under entry 68 of First Schedule taxable at 8%. Entry 99 held the field before 31.3.1992 and from 1.4.1992 onwards the above entry was rescheduled as entry 68 of First Schedule. Aggrieved by the order of the assessing authority holding that steel spring would fall under entry 99/68 of First Schedule to the Kerala General Sales Tax Act, assessee took up the matter in appeal before the Deputy commissioner (Appeals) who sustained the order of the assessing authority so far as steel spring is concerned with slight modification of the assessment order. Aggrieved by the same, assessee took up the matter in appeal before the sales Tax Appellate Tribunal. Appeals were allowed holding that as the round steel bars whether in straight length or coil form falls under Entry 2(ii) (d) of the second Schedule, the wire coils described as spring described as spring by the assessing authority would fall under the second schedule to the Kerala General Salestax Act taxable only at the rate of 4%. Appeals were allowed holding that as the round steel bars whether in straight length or coil form falls under Entry 2(ii) (d) of the second Schedule, the wire coils described as spring described as spring by the assessing authority would fall under the second schedule to the Kerala General Salestax Act taxable only at the rate of 4%. Holding so, Tribunal set aside the levy of tax on wire coils (springs) at the rate of 6% for 1991-92 and 8% for 1992-93 to 1996-97 and directed the assessing authority to levy tax at the rate of 4% on the sales turnover of wire coil (springs) for all the years. Aggrieved by the same, these tax revision cases have been preferred. Before examining the scope of entry 99/68 of the First Schedule to the Kerala General Salestax act and entry 2 (ii) (d) and 2 (ii) (f) of the second schedule to the Act, we may first examine the meaning and ambit of the words “steel spring” and how it is manufactured. Steel wire of specified SEG is twisted spirally by means of mechanical process at required lengths, normally varying from 9 to 25 inches and 3½ to 7 inches in diameter and both the ends of the spirally twisted spring are heated and forming hooked ends so as to enable to fasten with the wheel connected with the axle of the rolling shutter and due to this manufacturing process a commercially different commodity made of steel emerges. Dictionary meaning of the spring is also relevant. We may refer to the meaning given by New Websters’ Dictionary of English, which is extracted below: “Spring” is an elastic contrivance or body as a strip wire of steel coiled spirally which when comprised, bent or otherwise forced from its normal shape has the power of recovering this by virtue of its elasticity”. With the above meaning of the word in mind, let us examine the entries. We quote entry 99 and 68 for easy reference. With the above meaning of the word in mind, let us examine the entries. We quote entry 99 and 68 for easy reference. Entry 99: Iron and steel articles not mentioned At the point of first sale in state 6% elsewhere in this schedule or in the Entry 68: Iron arms, stay plates, and clamps, At the point of first sale in the state marine freight containers, G.I. Buckets and all other iron and steel articles not mentioned elsewhere in this schedule or in 8% the second schedule For a comparative study, we may also refer to the relevant entries: 2 (ii) (d): Steel bars (roundes, rods, squares, flats, octogon, hexagon, plain and ribbed or twisted in coil form as well as straight lengths. 2 (ii) (f): Sheets, Hoops, strips and skelp both black and galvanised, hot and cold rolled plain and corrugation all qualities, in straight length and coil form as rolled and in revited condition. Entries 99 and 68 give emphasise to the words “steel articles” which were not mentioned in the first or second schedule whereas several other items are included in entries 2 (ii) (d) and 2 (ii) (f) such as steel bars, sheets, hoops, strips and skelp but “steel spring” is omitted in those entries. The items specified in 2 (ii) and 2(ii) (f) in the second schedule are specific and “steel spring” the manufacturing process of which we have already mentioned earlier, is not included in the above entries. Entry 99/68 of first schedule specifically deals with steel articles not mentioned elsewhere. Since steel spring is not mentioned elsewhere it would fall under entry 99/68 of the first schedule to the Kerala General Salestax Act. Above is the view taken by the assessing authority as well as the Deputy commissioner (Appeals) with which we fully agree. Tribunal, in our view, has committed a grave mistake in not properly appreciating the scope and ambit of entries 99 and 68 of the first schedule to the Act. In such circumstances, we are inclined to allow these tax revision cases and set aside the order of the Tribunal. We answer the questions in favour of the Revenue.