KANAKARAJ, J.

For the year 1978-79, the assessee/respondent reported a total and taxable turnover of Rs. 83, 31, 314.91 and Rs. 83, 22, 376, respectively. The assessee claimed concessional rate at 3 per cent. on the sales of transformer oil to the tune of Rs. 7, 43, 883.79 on the production of form XVII prescribed under the proviso to section3(3) of the Tamil Nadu General Sales Tax Act, 1959. In other words the transformer oil was claimed as a component part in the manufacture of other goods inside the State by the person issuing the declaration form. The assessing authority proposed to reject the claim for the concessional rate and sought to levy at the rate of 8 per cent. and objections were called for. The assessee explained that the purchasing dealer that he was using the transformer oil as a component part and on the production of the declaration form the selling dealer (assessee) is entitled to the concessional rate of 3 per cent. However, the assessing authority relied on the circular issued by the erstwhile Board of Revenue in BPRT. 13/79 stating that transformer oil is not a component part of transformer and the concessional rate under section3(3) of the Act can