JUDGMENT
Jeevan Reddy, J.
1. The question that arises in this tax revision case is under which entry of which Schedule are the several goods mentioned hereinafter taxable.
2. The first goods concerned are transmission beltings. The department’s contention was that transmission beltings are chargeable as general goods under section 5(1) of the Act and not under entry 5 of the IV Schedule (exempted goods).
3. We have held in a recent case in T.R.C. No. 62 of 1985 disposed of on 9th June, 1988 [State of A.P. v. Goodyear India Ltd. [1989] 74 STC 47] that transmission beltings are “cotton fabrics” within the meaning of entry 5 of the Fourth Schedule to the A.P. General Sales Tax Act and accordingly exempt from the tax. Following the said decision, we hold that transmission beltings fall within the said entry 5 of the Fourth Schedule and accordingly are exempt from tax.
4. The next question is whether tractor-trailer wheels and axles are “wheels and axles” falling under entry 2(xiv) of the Third Schedule to the Act or under entry 50 of the First Schedule as it stood then.
5. Entry 50 of the First Schedule as it stood then read as follows :
“Tractors, bulldozers and parts thereof including tyres and tubes and accessories used therewith made of rubber or other materials.”
Entry 2(xiv) of the Third Schedule in so far as it is relevant reads as follows :
“Wheels, tyres, axles and wheel sets.”
We may mention here that entry 50 of the First Schedule was amended on 17th January, 1978 and the amended entry reads thus :
“Tractors, bulldozers and parts and accessories thereof including trailers and tyres and tubes made of rubber or other materials.”
6. A reading of entry 2(xiv) of the Third Schedule and entry 50 of the First Schedule shows that entry 2(xiv) of the Third Schedule is in the nature of a general entry and entry 50 of the First Schedule in so far as it refers to parts of tractors and bulldozers like tyres, wheels, etc., is in the nature of a specific entry.
7. It is relevant to mention that at the relevant time the trailers and their parts and accessories were not included in entry 50 of the First Schedule. A trailer is not an inseparable or inherent part or component of a tractor. A person purchasing a tractor may or may not purchase a trailer. A tractor does not necessarily include a trailer. Therefore, it is not possible to hold that even before 17th January, 1978, the trailers and their parts and accessories fell within entry 50 of the First Schedule. If they did not fall within entry 50 of the First Schedule, they naturally fell under entry 2(xiv) of the Third Schedule. This is the opinion expressed by the Tribunal and we agree with it.
8. The third goods concerned herein are animal drawn vehicle wheels, axles and trolley. Having regard to the nature of goods concerned herein which is set out in para 2 of the order of the Tribunal, we agree with the Tribunal that they fall within the ambit of entry 2(xiv) of the Third Schedule and are not taxable as general goods as contended by the department.
9. For the above reasons, the tax revision case fails and is accordingly dismissed. No costs. Advocate’s fee Rs. 150.
10. Petition dismissed.