K. L. SHARMA, J. - (1.) All these revisions have been filed under section 11 of the U. P. Sales Tax Act, 1948 (hereinafter referred to as "the Act" which includes the U. P. Trade Tax Act also), against the judgments and orders dated December 15, 1992, passed by the Sales Tax Tribunal, Saharanpur Bench, Saharanpur, Camp Dehradun, in Second Appeal Nos. 296 of 1992 (1991-92); 297 of 1992 (1991-92); 298 of 1992 (1991-92), 299 of 1992 (1991-92); 300 of 1992 (1991-92); 301 of 1992 (1991-92) and 302 of 1992 (1991-92) whereby the Tribunal has declared miniature filament bulbs manufactured by the respondent as unclassified items attracting tax liability at the rate of 9 per cent. I have heard Mr. R. D. Gupta, learned Standing Counsel for the applicant as well as Mr. Bharat Ji Agarwal, learned counsel for the respondent and perused the impugned judgments on record. The respondent is a private limited company carrying on the business of manufacture and sale of miniature filament bulbs. It is registered as a dealer under section 18 of the Act. It has filed the returns in form No. 4 declaring the turnovers for seven months beginning with April, 1991 and consequently seven provisional assessment orders have been passed by the assessing authority. The dealer filed appeals against the impugned orders of assessment and the Deputy Commissioner, Sales Tax (Appeals), dismissed the appeals. However, the learned Tribunal allowed the appeals by declaring the miniature filament bulbs as unclassified items attracting lower rate of tax at 8 per cent. The Commissioner, Sales Tax, U. P. , was not satisfied with the findings of the learned Tribunal and has preferred these revisions challenging the interpretation given by the Tribunal. Therefore the sole question arising for consideration in these revisions is whether the miniature filament bulbs manufactured and sold by the dealer are classified items or unclassified items. According to the learned Standing Counsel Mr. Gupta, the miniature filament bulbs are specially adapted for their use to the motor vehicles and as such they should have been treated as accessory to the motor vehicle and according to the Notification No. ST-2-5784/x-10 (1)/80 - U. P. Act 15/48 - Order-81 dated September 7, 1981, the items in question are included in the entry No. 43 and as such they are taxable at the rate of 10 per cent. Entry No. 43 of the said notification reads as follows : " 43 (1 ). Motor vehicles including motor cars, motor taxi cabs, motor cycles, motor cycle combinations, motor scooters, mopeds, motorettes, motor omnibuses, motor vans, motor lorries, motor trucks, jeeps, station wagons and chassis of motor vehicles and bodies or tankers or motor caravans built or meant for mounting on chassis of motor vehicles, but excluding tractors whether on wheels or on tracts. (2) Components, parts and accessories of vehicles specified in sub-entry (1) above including tyres and tubes, batteries and trailers adapted for use along with the said vehicles, other than such trailers as are predominantly used along with any other vehicles. " It is apparent from this entry that the miniature filament bulbs are not at all included in this entry. It is relevant to refer to entry No. 3 to the aforesaid notification which runs as follows : " All electrical goods, instruments, apparatus, appliances and all such articles the use of which cannot be had except with the application of electrical energy, including fans, fluorescent tubes (including their starters, chokes, fixtures, fittings and accessories), electrical earthenware and porcelain, electrical equipments, plants and their accessories required for generation, distribution and transmission of electrical energy, electric motors and parts thereof, and all other accessories and components, whether sold as a whole or in parts, but excluding torches, torchcells, dry cell batteries, torch bulbs and filament lighting bulbs. " The underlining has been done with a view to emphasise the items which have been expressly excluded from this entry. The torch bulbs, filament lighting bulbs have been excluded from this entry. A perusal of this entire notification shows that these bulbs or miniature filament bulbs have not been included in any other entry of the aforesaid notification. Therefore, by inference they become unclassified items. The learned Standing Counsel has submitted that since these miniature filament bulbs are also used in the motor vehicles as accessories with a view to beautify the vehicle and to make the vehicle more convenient for its use and for this reason alone these bulbs manufactured by the respondent fall within the clause (2) of entry No. 43 of the aforesaid notification. In order to support this criteria for interpretation the learned Standing Counsel has invited my attention to the decision of this Court in the case of Commissioner of Sales Tax, U. P. v. Roop Brothers 1979 UPTC 1288. In this case the question regarding classification of straps and chains manufactured and sold by the assessee had arisen. This Court referring to an earlier decision in the case of Annapurna Carbon Industries Co. v. State of Andhra Pradesh [1976] 37 STC 378 (SC); 1976 UPTC 488 considered the meaning of word "accessory" as approved by their Lordships of the honourable Supreme Court on the basis of its definition given in Webster's Third New International Dictionary which is to the following effect : " an object or device that is not essential in itself but that adds to the beauty, convenience, or effectiveness of something else. " This Court accepted the meaning of word "accessory" as given by W. A. Craig in the New English Dictionary in the case of Sales Tax Commissioner, U. P. , Lucknow v. Lachman Singh [1972] 30 STC 372; 1972 UPTC 144 defines as follows : " something attributing in a subordinate degree to a general result or effect; an adjunct or accompaniment. " The items involved in these cases were of course different ones and on facts the court held by applying the meaning of the word "accessory" to the said items and recorded finding whether the items were accessories or not. The learned Standing Counsel has further invited attention to a decision of this Court in the case of J. G. Rubber Manufacturing Company, Modinagar v. Commissioner of Sales Tax 1994 UPTC 501 in which the question arose whether the rubber flaps used in motor trucks and other heavy motor vehicles between the tyre and the wheel rim of a motor vehicle were deemed as accessory of a motor vehicle or fell outside the classification. In this case also this Court considered the dictionary meaning of the word accessory and the earlier decisions and recorded the view that if the item is an essential part exclusively adapted for use in the motor vehicle and is not ordinarily used for any other purpose of in any other device, it shall be treated as "accessory". On the facts and circumstances of the under-hand this Court held that the rubber flaps has to be treated as an accessory of motor vehicle by applying also one of the tests laid down by the honourable Supreme Court in the case of Mehra Bros. v. Joint Commercial Tax Officer [1991] 80 STC 233; AIR 1991 SC 1017. The learned Standing Counsel also placed reliance on a decision of the Bombay High Court in the case of Commissioner of Sales Tax v. Jayesh (India) Agencies [1984] 57 STC 128. In this case the rexine seat covers and rexine covers for doors, centre pillars, cowl pads and rear glass shelf made for motor vehicles came in for interpretation as the accessory to the motor vehicle. The court finding their exclusive use and adapted for their special use in a motor vehicle came to the conclusion that their use would certainly contribute to the beautification of the motor vehicle in which they are used and would add to the passengers' comfort in the motor vehicle and so also would the cowl pads. After going through the cases relied upon by the learned Standing Counsel and seeing the dictionary meaning of the word "accessory" the nature of the use of the item concerned becomes relevant for holding whether it is an accessory or an essential part of a particular appliance. The learned Tribunal has already gone into these facts and on page 18 of its judgment has recorded its clear-cut finding of fact in the following words : " The fact, however, is that filament lighting bulbs are meant to be used not only for motor vehicles but for various other uses, for instance, to be used in radios, rail, cycle dynamo, torches, flash lights, signal surgical instruments and they are also to serve as decorative bulbs, etc. The appellant in the present case has produced before us number of bills to show that he head sold bulbs produced by him to coal mining departments. If the department's contention is accepted then a filament lighting bulb will have to be taxed at different rate according to its use. If the bulbs are used in radios then it should have been treated as an accessory of the torches and so on. " I do not see any reason to differ with the findings of fact recorded by the learned Tribunal that the miniature filament bulbs manufactured and sold by the dealer are not exclusively used in the motor vehicles but they are variously used in different appliances. There is no doubt that the use of these filament bulbs adds to the beauty of the motor vehicle and also adds to the convenience in the use of the motor vehicle in dark night when the plying of vehicle becomes impossible without aid and assistance of a filament bulb. But this partial use and unnecessary beautification cannot make the item as an accessory of a motor vehicle only. As observed by the learned Tribunal these bulbs are being used in many other appliances like torches, radios, etc. , and if this partial use is to be treated as a dominating factor then same items would become accessories to other appliances also. The notification relied upon by the learned Standing Counsel regarding classification of the items makes the position clear that these filament bulbs have been expressly excluded from entry No. 3 and have not been included in any other entry of the aforesaid notification dealing with the motor vehicles and are thus excluded from every entry of the notification in force. Mr. Bharat Ji Agarwal, learned counsel for opposite party, has also placed reliance on the decision of this Court in the case of Commissioner of Sales Tax v. Geep Industrial Syndicate Ltd. 1989 UPTC 324, in which the question relating to dry cell battery arose whether they were unclassified items. This Court interpreted the notification dated December 7, 1979 and found that entry No. 32 expressly excludes dry cell batteries from the electrical goods and as such dry cell batteries were held to be unclassified items. Therefore the finding recorded by the learned Tribunal is perfectly in consonance with the provisions of the notification relied upon by the learned Standing Counsel. On the touchstone of accessory also, the items in question namely, filament bulbs cannot be treated as an accessory to the motor vehicles only as they are not exclusively used in or adapted for use in the motor vehicles only but they are variously used for different purposes in different electrical appliances. Had these bulbs been exclusively used in or adapted for use in the motor vehicles only either for the purpose of beauty, convenience or general effectiveness or as an adjunct or accompaniment, they could in that even be treated as an accessory to a motor vehicle but in view of the facts and circumstances of the present case and the findings of fact recorded by the learned Tribunal, the filament bulbs manufactured and sold by the respondent are not being exclusively used in or adapted for being exclusively used in the motor vehicles for either of the purposes like beauty, convenience, general effectiveness or as an adjunct or accompaniment. I therefore uphold the findings of fact and the interpretation rendered by the learned Tribunal that the filament bulbs manufactured and sold by the respondent are unclassified items attracting lower rate of tax. For the aforesaid reasons the revisions filed by the Commissioner of Sales Tax, U. P. , Lucknow do not have any merit and are hereby dismissed. The impugned judgments and orders dated December 15, 1992, passed by the Sales Tax Tribunal, Saharanpur Bench, Saharanpur, Camp Dehradun, in Second Appeal Nos. 296 to 302 of 1992, are hereby confirmed. Let an attested copy of this judgment be placed in the record of each of the revisions decided by this common judgment. Petitions dismissed. .;