Judgment :- D. MURUGESAN, J. 1. This tax case revision, at the instance of the Revenue, is filed questioning the order of the Tamil Nadu Sales Tax Appellate Tribunal (Additional Bench), Chennai in allowing the appeal filed by the respondent-assessee. 2. The respondent-assessee are the dealers of goods for indoor and outdoor games. They had sold the goods such as wisdom blocks, magnetic letters, animal and bird figures (plastic), rolled up black board etc. For the assessment year 1989-90, they reported a total and taxable turnover of Rs.21,97,667.50 and Rs.Nil respectively in the Form A1 returns under the TNGST Act. On verification of their account books, the assessing officer found that the above goods cannot be treated as indoor games goods or sports goods and therefore he determined the total turnover at Rs.22,19,235/-and the taxable turnover at Rs.15,88,106/-to be taxed at the rate of 5 per cent. Apart from the above, he also proposed to levy additional tax at the rate of 1.25 per cent, surcharge at the rate of 10 per cent and additional surcharge at the rate of 5 per cent. This order was questioned by the assessee before the Appellate Assistant Commissioner who, concurring with the views of the assessing officer, dismissed the appeal. The assessee took up the matter by way of further appeal before the Tamil Nadu Sales Tax Appellate Tribunal. The Tribunal found that the wisdom blocks, magnetic letters, animal and bird figures (plastic) can be considered as goods for indoor games or sports. To arrive at the said conclusion, the Tribunal referred to the supply of wisdom blocks to the primary schools, bird figures to the Tamil Nadu Small Industries Development Corporation Limited, animal figures to the Assistant Educational Officers of Chenglepet, Arcot and Salem Districts. The Tribunal also noticed several certificates issued by the educational institutions like M.Ct.Chidambaram Chettiar Memorial Preparatory School to the effect that the wisdom blocks, animal and bird figures (plastic) are used in nursery schools and these goods are used indoor by the children to learn by playing. The Tribunal also referred to the G.O.P.No.394, Commercial Taxes and Religious Endowments Department dated 25.4.86 exempting the goods for indoor games. This order is questioned in the present revision by the State. 3. The goods in question, namely, wisdom blocks, magnetic letters, animal and bird figures (plastic) are meant for the use of children. The Tribunal also referred to the G.O.P.No.394, Commercial Taxes and Religious Endowments Department dated 25.4.86 exempting the goods for indoor games. This order is questioned in the present revision by the State. 3. The goods in question, namely, wisdom blocks, magnetic letters, animal and bird figures (plastic) are meant for the use of children. Whether these goods can be considered as goods for indoor games or sports in terms of the amendment to the notification which came into force with effect from 17.3.86, as notified in G.O.P.No.394, Commercial Taxes and Religious Endowments Department dated 25.4.86, which provides exemption in respect of tax payable by any dealer on the sale of goods for indoor games or sports including toys, models, cups, trophies and badges? The goods for indoor games or sports cannot be given a restricted meaning inasmuch as the said items in the exemption notification includes the toys as well. The question is as to whether the dealer would be disentitled to claim the benefit of the notification merely because the goods are used for educational purpose. There are certain goods which are exclusively meant for education of children and there are certain goods which are exclusively meant for indoor/outdoor games or sports. The goods in question, though may not be considered to fall exclusively as indoor/outdoor games, the fact remains that these goods are used by the children to learn while playing. One of the better ways to educate children is by way of using colour cylinders, traditional building blocks, magnetic letters, rolling ball, toys, etc. Educating the children through play is one of the approved forms of education in all montessori schools. Merely because the goods in question are used for the purpose of education, those goods would not lose their character as goods of indoor games. The dealer had sold all these goods only to educational institutions which impart education to the children in their earlier years. The learning of education by the children through these goods is primarily by playing. Hence, the goods, namely, wisdom blocks, magnetic letters, animal and bird figures (plastic) are to be necessarily considered as goods for indoor games as notified in G.O.P.No.394, Commercial Taxes and Religious Endowments Department dated 25.4.86. Hence, we find no merits in the tax case revision and the same is dismissed. No costs.