(1.) ALTHOUGH before the Tribunal two assessment years - 1987-88 and 1988-89 - were the concern, it is 1988-89 which is the subject-matter of this petition. The petitioner-assessee returned a taxable turnover of Rs. 2,92,23,990. 60 for the year in question. The assessment was completed by the Sales Tax Officer.
(2.) THIS was challenged before the Appellate Assistant Commissioner, Trichur, on the ground that the assessee is eligible for reduction of tax payable on the sale of coconut oil cake to the extent tax was levied on the purchase turnover of copra by virtue of the Explanation to entry 51 of the First Schedule to the kerala General Sales Tax Act, 1963, from July 1, 1987. THIS contention was rejected and thereafter as a result thereof the matter was taken up before the Sales Tax Appellate Tribunal, Additional Bench, Palakkad.
(3.) READING the two entries along with the Explanation, as they are quoted hereinbefore, it would appear that the only way in which the Explanation can be understood would be that such reduction could not be considered in isolation, either with reference to coconut oil itself or with reference to coconut oil cake, depending on the choice of the assessee. The reason is simple that relationship between coconut oil, coconut oil cake and copra in regard thereto is to be understood on the basis of inter-connection thereof.