Judgment R. Sudhakar, J. 1. This Tax Case (Revision) is filed by the Revenue as against the order of the Sales Tax Appellate Tribunal, Puducherry dated 29.1.2014 for the assessment year 2003-04. 2. The short issue that arises for consideration in this Revision is whether the respondent/assessee is entitled to claim concessional tax at 3% as against 12% on the basis of G.O.Ms.No.20/2000/F2, Finance Department dated 27.5.2000. 3. The assessment in this case relates to the assessment year 2003-04. The respondent/assessee is a dealer in lubricants and grease. The assessee claimed concessional levy of tax at the rate of 3% on the sale of lubricants to the industries as input as per G.O.Ms.No.20/2000/F2, dated 27.5.2000. The Assessing Officer verified the invoices for the supply of lubricants to the industries by the assessee and rejected the claim made by the assessee holding that the lubricants sold by the assessee were not used as input by the industries, which bought the lubricants from the assessee, instead they used the same to lubricate the machine. Hence, the Assessing Officer held that the assessee is not entitled to the benefit of G.O.Ms.No.20/2000/F2 of Finance Department dated 27.5.2000 and assessed tax at the rate of 12%. Aggrieved by the same, the assessee filed an appeal before the Appellate Assistant Commissioner, who dismissed the appeal, thereby confirming the order of the Assessing Officer. As against the said order, the assessee preferred further appeal before the Puducherry Sales Tax Appellate Tribunal. The Tribunalaccepting the contention of the assessee allowed the appeal holding that the manufacturing process of an industry starts from the operation of machine which needs lubricants to lubricate the machine and therefore lubricant is an input in terms of G.O.Ms.No.20/2000 F2 of Finance Department dated 27.5.2000. Therefore, the assessee is entitled for the benefit of concessional levy. Aggrieved by the same, the Revenue is before this Court. 4. Heard learned Additional Government Pleader appearing for the petitioner and perused the materials placed before this Court. 5. Learned Additional Government Pleader appearing for the petitioner submits that the assessee in this case sold the lubricants to industries, which did not use it as inputs. Aggrieved by the same, the Revenue is before this Court. 4. Heard learned Additional Government Pleader appearing for the petitioner and perused the materials placed before this Court. 5. Learned Additional Government Pleader appearing for the petitioner submits that the assessee in this case sold the lubricants to industries, which did not use it as inputs. As per G.O.Ms.No.20/2000 F2 of Finance Department dated 27.5.2000, lubricants when sold and which are used in the manufacturing process of concerned user industry alone are entitled for the benefit of the above-said G.O. The lubricants sold by the assessee in the present case to the industries were not used in the manufacturing process, but only used to lubricate the machine for the purpose of running their industry. Hence, the assessee is not entitled for the benefit of concessional levy. 6. We have perused the order of the lower Authority, first Appellate Authority and that of the Tribunal. It is seen that as per G.O.Ms.No.20/2000 F2 of Finance Department dated 27.5.2000, lubricants sold as inputs to industries qualify for concessional levy of 3% of tax. It is relevant to note that the above-said G.O. speaks about inputs sold to industries located in Union Territory of Puducherry. It does not qualify as to whether the inputs should be used in the manufacture of goods or otherwise. For better clarity, the relevant portion of G.O.Ms.No.20/2000 F2 of Finance Department dated 27.5.2000, as extracted in the order of the Tribunal, reads as follows: "the Lieutenant Governor, Pondicherry being satisfied that it is necessary so to do in the public interest is pleased to reduce the rate of tax to 3% in respect of lubricating oils, all kinds of mineral oil etc., sold as inputs to the industries located in the Union Territory of Pondicherry" (emphasis supplied) 7. The language of the above-said G.O. is plain and simple that it should be sold to industries which use it as inputs and those industries should be located in Union Territory of Puducherry. There is no dispute that the industries, which bought the lubricants from the assessee for the purpose of running their industry are located in the Union Territory of Puducherry. The G.O. does not speak as to how the inputs should be used and therefore, the Revenue cannot import some other meaning into the G.O. than what is stated therein. There is no dispute that the industries, which bought the lubricants from the assessee for the purpose of running their industry are located in the Union Territory of Puducherry. The G.O. does not speak as to how the inputs should be used and therefore, the Revenue cannot import some other meaning into the G.O. than what is stated therein. The G.O. does not state that the goods sold should be used as inputs in the manufacture of goods produced by the said industry. If it were so, then there is a case for the Revenue. Wherever the Legislature wanted to define inputs, it specifically done so indicating certain goods as inputs and certain goods as not inputs. For this proposition, we can draw an analogy from Rule 57B of the the Central Excise Rules, which reads as follows: "Rule 57B. Eligibility of credit of duty on certain inputs. (1) Notwithstanding anything contained in rule 57A, the manufacturer of final products shall be allowed to take credit of specified duty paid on the following inputs, used in or in relation to the manufacture of the final products, whether directly or indirectly and whether contained in the final products or not, namely:- i. inputs which are manufactured and used within the factory of production; ii. paints; iii. inputs used as fuel iv. inputs used for generation of electricity or steam, used for manufacture of final products or for any other purpose, within the factory of production; v. packing materials and materials from which such packing materials are made provided the cost of such packing materials is included in the value of the final product; vi. accessories of the final product cleared along with such final product, the value of which is included in the assessable value of the final product. Explanation – For the purposes of this sub-rule, it is hereby clarified that the term 'inputs' refers only to such inputs as may be specified in a notification issued under rule 57A. (2) The manufacturer of the final products shall not be allowed to take credit of the duty paid on the following goods, namely :- i. machines, machinery, equipment, apparatus, tools, appliances or capital goods as defined in rule 57Q (other than those used as component parts in the manufacture of final products), used for any purpose in the factory; ii. (2) The manufacturer of the final products shall not be allowed to take credit of the duty paid on the following goods, namely :- i. machines, machinery, equipment, apparatus, tools, appliances or capital goods as defined in rule 57Q (other than those used as component parts in the manufacture of final products), used for any purpose in the factory; ii. packing materials in respect of which any exemption to the extent of the duty of excise payable on the cost of the packing materials is being availed of for packing nay final products; iii. packing materials or containers, the cost of which is not included in the value of the final products under section 4 of the Act and iv. crates and glass bottles used for aerated water." 8. If the assessee is able to show that the goods sold to industries located in Union Territory of Puducherry, they are entitled to the benefit of G.O. If the said user industry uses it as input in any manner, then the benefit will flow there form. The G.O. does not qualify as to how inputs should be used. All that it states is that it should be input for industry in general terms. Hence, we find no error in the order of the Tribunal. Accordingly, we see no question of law much less any substantial question of law arises for consideration in this Revision. This Tax Case (Revision) stands dismissed. No costs. Consequently, M.P.No.1 of 2014 is also dismissed.