1. The only question which arises in this Tax Revision Case is whether copper wire is a component part of electrical transformers, The Sales Tax Officer held that it was not, and his decision was confirmed in appeal by the Appellate Assistant Commissioner as well as by the Sales Tax Appellate Tribunal.

2. The assessee is a dealer is copper wires and other goods. He sells copper wires to the Indian Transformers, Ltd., Alwaye. It is not disputed that these wires are used by the buyers in the process of manufacturing transformers. During the assessment year 1966-67 the assessee sold copper wires for a total sum of Rs. 1, 75, 843.82 to the Indian Transformers. Ltd., and furnished to the department declarations in Form 18 for the purpose of availing himself of the concessional rate of 1 % in terms of sub-section (3) of S.5 of the Kerala General Sales-tax Act, 1963, for short, the Act. We shall read sub-section (3): "(3) Notwithstanding anything contained in sub-section (1) or sub-section (2), the tax payable by a dealer in respect of any sale of the goods mentioned in the First Schedule by such dealer to another for use by the latter at component part of any other goods menti