JUDGMENT : Saumitra Dayal Singh, J. These revisions have been filed by the revisionist-assessee against the common order of the Commercial Tax Tribunal, Meerut dated 14.3.2012 passed in Second Appeal No.153 of 2005 for the A.Y. 2001-02 (Entry Tax); Second Appeal No.223/2008 for the A.Y.2002-03 (Entry Tax) and Second Appeal No.224 of 2008 for A.Y. 2003-04 (Entry Tax) as also two departmental appeals being Second Appeal No.236 of 2011 and 176 of 2011 for A.Y. 2005-06 and 2006-07 (under Entry Tax). By that order, the tribunal has dismissed all the appeals. 2. For the sake of convenience, the facts in Second Appeal No.153 of 2005 for A.Y.2001-02 (Entry Tax) are being noted. 3. In brief, during the assessment year in question, the assessee, a public limited company, was engaged in providing telecommunication services under an appropriate license issued under the relevant law. For the purposes of its business, it imported electronic goods, computer goods, generators, telecommunication parts, SMPS Power Plant, electrical goods, telecom equipment and SIM cards etc. This is the exact description given to the goods subjected to the entry tax, in the order dated 30.6.2004. No other, further or detailed disclosure of the exact goods has been made by any of the authorities before subjecting the assessee to tax on such goods. These goods were subjected to tax treating the same to be machinery value of Rs.10 lac or more, falling under the schedule Item No. 2 to the schedule appended to the U.P. Tax on Entry of Goods Act, 2007. The same has been upheld by both authorities. 4. Heard Sri Bharat Ji Agrawal, learned senior Advocate assisted by Sri Ashish Mishra, learned counsel for the assessee-revisionist and Sri B.K. Pandey learned standing counsel for the respondent-revenue. 5. Present revisions have been pressed on the following question of law: "Whether the equipment in question which has been held to be an electronic equipment would be covered by item no. 5 machinery and spare parts of machinery of Schedule referred in Section 4(1) of the U.P. Tax on Entry of Goods Act?" 6. It is to be noted that taxing entry under the provisions of Entry Act, 2007 (hereinafter referred to as the Entry Tax Act) was entry no. 2. It reads as below: "2. Machinery and spare parts of machinery valuing Rupees Ten Lac or more." 7. It is to be noted that taxing entry under the provisions of Entry Act, 2007 (hereinafter referred to as the Entry Tax Act) was entry no. 2. It reads as below: "2. Machinery and spare parts of machinery valuing Rupees Ten Lac or more." 7. Admittedly, the word machinery or the spare parts of machinery has not been defined under the Entry Tax Act. Referring to Section 2 (2) of the Entry Tax Act, it has been submitted the words and expressions used under the Entry Tax Act, but not defined, would have to be given the same meaning as assigned to such words and expressions under the U.P. Value Added Tax Act 2008 (hereinafter referred to as the VAT Act). Relying on the various scheduled entries falling under Part-A and Part-B of the schedule to the VAT Act, it has been submitted that I.T. Products (as mentioned in Part B) including computers, telephones and parts thereof, cell phones, satellite receivers, DVD, CD, teleprinter and wireless equipment and parts thereof; transmission wire and towers, telecom tower, Electrical apparatus for line telephony or line telegraphy including line telephone sets with cordless hand sets and telecommunication apparatus for carriage-current line system or for digital line system; video phones, even if these be machinery in common understanding, would stand excluded from the taxing entry of 'machinery' falling under Part-A entry 26 of the Vat Act, by virtue of Section 2(2) of the Entry Tax Act. Reliance has been placed on a decision of Supreme Court in the Case of Godfrey Phillips India Ltd. And Another Vs. State of U.P. And Others, (2005) 2 SCC 515 , wherein it has been reasoned and held that taxable events separately provided for under separate taxation entries, cannot be mingled. There can be no overlapping in such matters and if tax is specifically provided for under one legislative entry, it effectively narrows the fields of taxation available under other related entries. Thus, it has been submitted that in so far as the Vat Act is concerned, there can be no doubt or dispute that items falling under schedule entry Nos. 63 and 127 of Part-A of the Schedule and Item No.27 of Part-B of the Schedule of the VAT Act, would have to be necessarily excluded from the entry of machinery under Part-A, entry No. 26 of the Schedule to the VAT Act. 63 and 127 of Part-A of the Schedule and Item No.27 of Part-B of the Schedule of the VAT Act, would have to be necessarily excluded from the entry of machinery under Part-A, entry No. 26 of the Schedule to the VAT Act. Same position would prevail under the entry tax as well by virtue of section 2 (2) of that Act. 8. In so far as iron, steel and other cable items are concerned, it has been submitted that the same would in any case, stand excluded from the entry of machinery irrespective of the above reasoning. Thus, telecom towers, transmission wire, electrical apparatus etc. are stated to be not machinery at all. Alternatively, it has also been submitted that w.e.f. 30.9.2008, the schedule under the Entry Tax Act, was itself amended whereby iron and steel as defined under Section 14 of the Central Sales Tax Act, 1956, cables of all kinds, laptop, the computer system and peripherals or televisions, were separately specified under Schedule Entry Nos.14, 16, 17 and 20 of the schedule to the Entry Tax. The present assessments being for the period prior to that amendment, it has been canvased, in any case, the items falling under the amended entries could never be subjected to tax prior to the taxing entry. 9. Learned Standing Counsel for the respondent-revenue has opposed the revision and submitted that the reasoning of the Tribunal cannot be faulted, in so far as the Tribunal has reasoned that machinery does not exclude electronic machinery and has followed its earlier decision which is consistent with a decision of learned Single Judge of this Court in the case of M/s Door Sanchar Maha Prabandhak, Bharat Sanchar Nigam Ltd. Vs. Commissioner Commercial Taxes in Trade Tax Revision No.75 of 2010 decided on 02.11.2012. Therefore, no interference is warranted by this Court and the question of law may be decided against the assessee. 10. Having heard learned counsel for the parties and having perused the record, as a general principle/rule, it cannot be denied that certain electronic goods may qualify as electronic machinery as understood by the men who deal in the same. However, that rule or principle may not be sufficient or decisive. 10. Having heard learned counsel for the parties and having perused the record, as a general principle/rule, it cannot be denied that certain electronic goods may qualify as electronic machinery as understood by the men who deal in the same. However, that rule or principle may not be sufficient or decisive. What is required to be examined is whether in the facts of the present case, all the commodities that the assessee disclosed to have dealt in being electronic goods, computer goods, generators, telecommunication parts, SMPS Power Plant, electrical goods, telecom equipment and SIM cards etc., were such as may be described as electronic machinery and therefore, machinery. 11. It has completely remained from the Tribunal to consider and decide this issue. The issue was essential to be dealt with and decided by the Tribunal separately in view of the fact that it is not a composite form or bill value of the goods that may determine the occurrence of the taxable event but the value of the individual machinery or part was required to be established to be Rs.10 lac or more. Therefore, unless the categorical finding was first recorded by the Tribunal that the assessee imported identified machinery of value more than 10 lac, the issue of taxable event could never get decided. 12. Then, even if the Tribunal were to find that one or more machinery of value Rs.10 lac or more was imported by the assessee, yet, it would have to further examine the objection raised by the assessee that the same would stand excluded by virtue of separate entries under the VAT Act providing for separate treatment of such machinery under that Act. In other words, even if one of the electronic machinery say ('x') imported is found to have been imported by the assessee which is of value Rs.10 lac or more, the Tribunal would have to further examine whether such electronic machinery ('x') was taxable as machinery under the VAT Act or as any other commodity falling under a separate schedule entry under the VAT Act. If the conclusion to be drawn by the Tribunal be that such machinery ('x') was taxable under a separate schedule entry under the VAT Act, it would be further required to examine whether on such distinction under the VAT Act, the commodity would continue to remain taxable as machinery under the Entry Tax Act or it would cease to be taxable on that reasoning. 13. At present, though the Tribunal has touched this issue but its findings are not reasoned. The issue that has been canvased by the assessee in the present revision, has not been squarely dealt with. In any case, since the matter is proposed to be remitted to the Tribunal, the same may be re-adjudicated. 14. As to the alternative submission advanced by the counsel for the revisionist-assessee, again there is no discussion by the Tribunal in the impugned order. 15. Inasmuch as, at present, order passed by the Tribunal does not appear to have dealt with the aforesaid issue, the question of law framed by this court, cannot be answered at this stage. The order of the Tribunal is, thus, set aside. The revision is disposed of. The matter is remitted to the Tribunal to pass a fresh order, preferably, within a period of four months in accordance with law after hearing the parties on the strength of evidence existing on record.