Judgment :- Radhakrishnan, J. Following are the questions of law raised by the appellant for our consideration. 1. Whether the respondent commissioner is justified in clarifying that Video Conferencing Equipments are taxable at the rate of 12.5% particularly when the HSN code of the same is 8517.50.99 and items having HSN code 8517.50 are taxable aft the rate of 4% and as per Rules of Interpretation the commodities which are given four digit HSN number shall include all those commodities coming under that heading of the HSN? 2. Whether the respondent commissioner is justified in clarifying that Video Conferencing Equipments are taxable at the rate of 12.5% stating that they are electronically related digital on line system and would never fall under HSN code 8517.50 ignoring the fact that the item in question is having HSN code 8517.50.99 as per Central Excise & Customs Tariff Manual? Assessee had filed an application for clarification under section 94 of the Kerala Value Added Tax Act 2003 on the rate of tax applicable to Video Conferencing products and multifunction printers vide their application dated 6.7.05 before the Commissioner of Commercial Taxes. Commissioner of Commercial Taxes vide order dated 18-1-06 clarified that Video Conferencing Products, Multi Function Printers etc. would fall under RNR category attracting tax at the rate of 12.5%. Assesse later filed an application to reconsider the order dated 18-1-06 to the effect that Video Conferencing Products and Multifunction Printers are taxable at the rate of 4%. Assessee had stated that as per entry 69(29)(g) of 3rd Scheduled of the Act, other apparatus for carrier current line systems or for digital line systems with HSN Code 8517.50 will attract tax at the rate of 4% and thus Video Conferencing Equipments with HSN 8517.50.99 will also rightly fall under the above entry with tax at the rate of 4%. Commissioner examined the claim raised by the assessee. It was noticed that Video Conferencing Equipments also known as video tele conference equipments is a set of interactive telecommunication technologies which allow two or more locations to interact via two way video and audio transmission simultaneously. Further it was also noticed that a video conferencing terminal must have a few basic components like a camera, a video display, a microphone and speakers. Further it was also noticed that a video conferencing terminal must have a few basic components like a camera, a video display, a microphone and speakers. In addition to these, other components like codec, a user interface, a computer system to run on and a network connection is also used. It was pointed out that HSN 8517.50 indicates “other apparatus for carrier current line system or for digital line system” what is mentioned under the HSN 8517.50 are purely electrically related equipments. Video Conferencing Equipments, on the other hand, are electronically related digital on line system and the same will never fall under the HSN 8517.50. Commissioner therefore found no reason to modify the clarificatory order issued on 18-1-06. Aggrieved by the same this appeal has been preferred. 2. Counsel appearing for the appellant submitted that when an item having a particular HSN code is included in the schedule of KVAT Act, 2003, all the items falling in the sub headings of that item as per Contra Excise Tariff Manual shall also be treated as items falling in the entry in that Schedule. Counsel submitted that Video Conferencing Products is an item having HSN Code 8517.50.99. Counsel further submitted that Video Conferencing Products would fall under entry 69(29g) to the III Schedule of Kerala Value Added Tax Act and that the assessing authority cannot ignore HSN Code 8517.50. Reference was also made to the Rules of Interpretation appended to the Kerala Value Added Tax Act 2003. 3. Special Govt. Pleader (Taxes) Shri V.V. Ashokan appearing for the revenue on the other hand, contended that there is no distinct/separate HSN Code for Video Conferencing Equipment and that it is an admixture/combination of various independent items. Further it is stated that since Video Conferencing Equipment as such is not described or classified under Schedules ll or lll of the KVAT Act, the commodity is leviable to tax at the rate of 12.5% in the teeth of Section 6(1)(b) of the Act. It was also pointed out that no stretch of imagination it could be held that Vide Conferencing Equipments can be classified as an item having description under HSN 8517.50. Counsel further submitted that the appeal itself is not maintainable since the assessee had not filed appeal against the original clarificatory order passed by the Commissioner. 4. We have gone through HSN Code referred to by the counsel for the assessee. Counsel further submitted that the appeal itself is not maintainable since the assessee had not filed appeal against the original clarificatory order passed by the Commissioner. 4. We have gone through HSN Code referred to by the counsel for the assessee. We are of the view, Video Conferencing Products would not fall within HSN Code 8517.50. Video Conferencing Equipments are electronically related digital on line system and is a set of interactive telecommunication technologies which allow two or more locations to interact via two way video and audio transmission simultaneously. A Video Conferencing Terminal must have a few basic components like a camera, a video display, a microphone and speakers. In addition to these, there is also a codec, a use interface, a computer system to run on and a network connection etc. all the above mentioned item are “electronically related digital on line system” and HSN Code 8517.50 relates only to the “electrically related equipments.”. HSN Code 8517.50 is assigned to entry 69(2)(g) which is purely “electrically related equipments”, but video conferencing equipments are electrically related digital on line system which will never come under HSN 8517.50. Therefore it would fall only under NR category attracting tax at the rate of 12.5% as provided under section 6(1) (d) on the Act. Under such circumstance we find no error in the clarificatory orders passed by the Commissioner. Questions of law are answered against the assessee. Appeal lacks merits and the same would stand dismissed.