K. JAGANNATHA SHETTY, J.

( 1 ) THIS revision petition raises an important and interesting question as to whether "car seat covers" could be considered as accessories of motor vehicles within the scope of Entry No. 73 of the Second schedule to the Karnataka Sales Tax act ('act' called shortly ). Entry No. 73 : 'articles used generally as parts and accessories of motor vehicles-13 percent. Note :-Reduced to 12 per cent by act 7/81. Counsel for the petitioner states that the car seat covers are accessories only of a part of the car viz. , the seats and they, therefore, cannot be, termed as accessories of motor vehicles.

( 2 ) THE contention demands a close analysis but before we dissect that entry, it is necessary to state the facts of the case. They are as follows.

( 3 ) THE Petitioner is a dealer registered under the Act. For the year ending March 31, 1975, the petitioner filed a return with taxable turnover of Rs. 2,50,469/-relating to the sale of car seat covers. The assistant Commissioner of Commercial Taxes before whom the return was filed, assessed that part of the turnover at 3-1/2 per cent under S. 5 (1) of the Act on the ground that the seat covers are just accompaniments to

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