JUDGMENT (Per R. Gururajan, J.) M/s. Associated Cement Companies Limited, is before us in this Revision Petition raising the following questions of law on the following facts : (1) Whether the Karnataka Appellate Tribunal was right in law in confirming the order dated 27.2.2004 of the Joint Commissioner of Commercial Taxes (Appeals), Bangalore City Division I, Bangalore ? (2) Whether the Hon'ble Karnataka Appellate Tribunal has erred in holding that Entry Tax at 2% on the value of Electrical Spare Parts purchased for Thermal Generating Sets for captive generation of power is leviable, treating the same as machinery ? (3) Whether Entry Tax at 2% has been levied without authority of law on the value of Cement Bags brought from outside the State of Karnataka between 1.4.1997 and 6.1.1998 and subsequently sold in the State of Karnataka ? (4) Any other question of law this Hon'ble Court deems fit in the facts and circumstances of this case ? The Petitioner is a Company registered under the Companies Act, 1956 and is covered by the Karnataka Sales Tax Laws. It is a dealer engaged in the activity of manufacture and sale of Cement in the State of Karnataka. The Assessing Authority - Deputy Commissioner of Commercial Taxes (Assessments 11), Fast Track, Bangalore concluded the Assessment Order for the Assessment Year 1997-98 levying tax, among others on the following - (a) Tax at 2% on the value of Electrical Spare Parts valued at Rs. 17,34,924/- purchased for Thermal Generating Sets and Diesel Generating Sets for captive generation of power, has been wrongly levied Entry Tax, treating the same as machinery. The Electrical Spare Parts cannot be classified as Machinery under the notifications dated 23.9.1998 and 7.1.1998. (b) Tax at 2% has been wrongly levied on the value of Cement Bags of Rs. 5,34,87,275/- brought from outside the State of Karnataka for sale between 1.4.1997 to 6.1.1998 and sold in the State of Karnataka, which was not liable to Entry Tax in view of the decision of the Hon'ble High Court of Karnataka. Matter was taken before the Appellate Authority. Appeals were filed before the Joint Commissioner of Commercial Taxes (Appeals) and Appeal stood rejected. Thereafter, Appeals were filed before the Tribunal. Tribunal dismissed all the Appeals. It is in these circumstances, the Assessee is before us by raising the above questions of law. Matter was taken before the Appellate Authority. Appeals were filed before the Joint Commissioner of Commercial Taxes (Appeals) and Appeal stood rejected. Thereafter, Appeals were filed before the Tribunal. Tribunal dismissed all the Appeals. It is in these circumstances, the Assessee is before us by raising the above questions of law. Heard Sri Vikram A. Huilgol, learned Counsel appearing for the Petitioner. He takes us to the material on record to say that all the three Authorities are wrong in holding against the Assessee. According to him, that the Petitioner has purchased Thermal Generating Sets and Spares. Spare parts for DG Sets is exempt from levy of tax and they cannot be classified as machinery. DG Sets are classified as electrical goods. He further says that the Authority without properly understanding the material on record has chosen to levy tax on the value of electrical parts purchased for Thermal Generating Sets treating the same as machinery. He relies on a number of judgments. Per contra, Smt. Sujatha, learned Government Advocate says that in the light of the specific entry available in terms of Entry 52 of the First Schedule under the Karnataka Tax on Entry of Goods Act, 1979, the Authorities are right in levying tax under Entry 52. She says that Entry 28 is not available to the Petitioner. After hearing, we have carefully perused the material placed on record. Admitted facts would reveal that the Petitioner has purchased spare parts for its Thermal Generating Set for generating power for captive consumption. The same was treated as machinery and tax was levied. When the same was challenged, all the three authorities have chosen to hold that tax is leviable at 2% treating the same as machinery. Let us see as to whether the tax on the basis of machinery is permissible or not. Entry 28 of the Entry Tax Act would read as under : "Electrical and electronic goods, appliances, instruments and apparatus and parts and accessories thereof but excluding those specified elsewhere". Entry 52 of the Entry Tax Act would read as under : "Machinery (all kinds) and parts and accessories thereof but excluding agricultural machinery". All the three Authorities after noticing the specific entry in terms of Entry 52 has chosen to levy tax on the basis of the goods falling under Entry 52 of the Act. Entry 52 of the Entry Tax Act would read as under : "Machinery (all kinds) and parts and accessories thereof but excluding agricultural machinery". All the three Authorities after noticing the specific entry in terms of Entry 52 has chosen to levy tax on the basis of the goods falling under Entry 52 of the Act. The Petitioner relies on the judgment of the Bombay High Court in Hind Rectifiers Limited v. State of Maharashtra, (1981) 47 STC 303 (Bom.) (DB). In the said case, the Court was concerned with the manufactured rectifiers in terms of the material facts. After noticing the material facts, the Court ruled that the Rectifiers sold by the Assessee had a direct nexus with the utilisation of electricity and both from the common sense point of view and point of view. Bharat Vijay Mills Limited v. Commissioner of Commercial Taxes, 1991 (35) Kar. L.J. 18 (HC) : (1992) 85 STC 23 (Kar.), is a judgment with regard to interpretation of statutes. 1990 STC 129 , is also a case dealing with interpretation of statute. The Petitioner also relies on a judgment of this Court in the case of P. R. Chindak and Others v. Assistant Commissioner of Commercial Taxes (Appeals), Belgaum and Others, 1993 (37) Kar. L.J. 427 (HC) (DB) : (1994) 93 STC 139 (Kar). (DB). In that case also, the Court was considering with regard to interpretation of taxing statutes. But the fact of this case would show that there are two entries available on record. The special entry of machinery would cover spare parts as well. In these circumstances, the general entry of electrical goods cannot be pressed into service by the Assessee for the purpose of taxation. In fact in the said judgment, the Court ruled that a special entry over-ruled general entry. The Court has ruled as under : "If there are two entries and one entry is broader and covers the entire class of goods, while the other entry covers some of the goods out of the said class the latter entry should be considered as a special entry in respect of those goods. In such a situation, the special entry would cut down the scope of the general entry, so that both the entries could be read harmoniously and given effect to". This judgment supports the Revenue. In such a situation, the special entry would cut down the scope of the general entry, so that both the entries could be read harmoniously and given effect to". This judgment supports the Revenue. Recently, a Division Bench of this Court in (2006) 146 STC 681 (Kar.), has considered Entry 56, Schedule VII and after noticing the Division Bench has ruled that Diesel Generating Sets are to be classified as machinery. Despite their generating electricity they are not Electrical Goods. In the light of this law available on record and in the light of the special entry available again in favour of Revenue, we are of the view that no legal errors as such are committed by any one of the Authorities. Orders are acceptable in law. In the result, this petition stands rejected. Questions of law are answered against the Assessee. No costs.