K.A. SWAMI, C.J.

This appeal is preferred against the order dated January 5, 1993, passed by the Joint Commissioner (SMR) of Commercial Taxes, Madras, in Ref. No. T2/2444/92 under section37 of the Tamil Nadu General Sales Tax Act, 1959, hereinafter referred to as "the Act".

2. The contention of the appellant/assessee is that there is no finding recorded by any of the authorities below that the appellant purchased the motor and grinder separately and assembled them into one as wet grinder, even though it is the case of the assessee that he is not selling any wet grinder and is selling only the electric motor and the grinder separately; therefore, the tax assessed on the basis of the entry No. 41-E of the First Schedule to the Act is not permissible in law. It is not possible to accept this contention in the light of the finding recorded in paragraph 12 of the order of the Joint Commissioner (SMR) which reads thus :

"On facts, it is found with reference to the list furnished before me that the goods were sold only to consumers in single bill. Even in common parlance or trade practice, no consumer will take the grinder and motor separately, but he would normally satisfy himse