RAMASWAMI, J.

The assessee-company is a dealer in rice-huller and flour-mill machineries. For the assessment year 1973-74, it claimed exemption from sales tax in respect of a turnover of Rs. 4, 093.63 relating to sales of hair-beltings and cotton-beltings. So far as the hair-belting is concerned, the certificate produced by the assessee from the Government of India National Test House, Alipore, Calcutta, showed that the ratio of the content of hair and cotton in hair-belting was 50 : 50. The claim was overruled on the ground that the particular item would fall under item 81 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, as "parts and accessories of machinery" and as such taxable, and that it will not fall under item 4 of the Third Schedule exempt from tax. Item 4 of the Third Schedule at the relevant time read as follows

"All varieties of textiles (other than durries, carpets, druggets and pure silk cloth) made wholly or partly of cotton, staple fibre, rayon, artificial silk or wool including handkerchiefs, towels, napkins, dusters, cotton velvets and velveteen, tapes, niwars and laces and hosiery cloth in lengths."

The question for consideration, the