RAMANUJAM, J.

These cases arise in relation to the same assessee, but for two different years. In the two years, the assessee has been taxed on its sales of cycle seat covers treating them as sales of accessories to cycles covered by item 38 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959. The assessee's contention that the seat covers sold by him cannot be treated as accessories to cycles and as such the sales are subject to multi-point tax alone was rejected by the assessing authority. This view has not been accepted by the Tribunal. The Tribunal has taken the view that cycle seat covers which are manufactured by the assessee and sold cannot be treated as accessories or parts of bicycle so as to bring them within item 38 of the First Schedule to the Act and, therefore, the goods are liable to only multi-point tax.

Revenue contends before us that the decision of the Tribunal cannot be sustained in view of the decision of this court in T.C. No. 107 of 1971 (Khetty Traders v. State of Madras wherein seat covers for cars have been held to be automobile accessories. In that case also, it was contended that the seat covers are not necessary at all for runn