Satish Chandra, J. - (1.) HEARD Sri Sanjay Sarin appearing for the department and Sri S.M.K.Chaudhary for the assessee. The brief facts of the case are that the assessee is engaged in manufacturing and sale of Titanium Metal anodes. The assessee also took the repair works of the Titanium Metal anodes during the guarantee period after having some charges. The assessee made an application dated 30.9.1991 before the Commissioner, Trade Tax under Section 35 of Trade Tax Act, 1948 to know the rate of tax on the sale of Titanium Metal anodes. Further it was asked by the assessee that if the Titanium Metal anodes are re-coated or repaired during the guarantee period, any tax is chargeable or not. The Commissioner treated the application for the Assessment Year 1991-92 and observed that the matter pertaining to the Central Sales-Tax department has already started, so for this assessment year under consideration 1991-92, the opinion cannot be given for the reason that the matter is already sub judiced. Not being satisfied, the assessee has filed an appeal before the Tribunal. The Tribunal vide its impugned order dated 24.7.1995 observed that Titanium Metal anodes requires re-coating and repair. The assessee is re-coating and repairing the Titanium Metal anodes, which is highly technical, during the guarantee period after having the necessary charges. The same does not attract the tax because it is not a sale, it is merely a repair work. Not being satisfied, the department is before this Court. With this background, I have heard learned counsel for both the parties and gone through the material available on record. From the record, it appears that the Tribunal has rightly observed that during the guarantee period, re- coating and repair of Titanium Metal anodes is not a sale. This is merely a repair work, so no tax can be charged. The Tribunal has relied on a number of case-laws in its order, which are not required to repeat here. In the facts and circumstances of the case, I find no reason to interfere with the Tribunal's order. No substantial question of law emerges. The revision is liable to be dismissed. The revision filed by the department is hereby dismissed.;