JUDGMENT

K. RAMASWAMY, J.:— This appeal by special leave is against the judgment of the Division Bench of the Kerala High Court dated -October 17, 1984 made in T.R.C. No. 73 of 1984. The respondent is a registered dealer under the Kerala General Sales Tax Act, (for short the Act). For the assessment year 1975-76 the respondent filed a return on taxable turnover of Rs. 39,376.32 as against the turnover of Rs. 58,130/ - excluding a sum of Rs. 72,787.87, the value of coconut husks purchased by the assessee and converted into the coconut fibre. The respondent claimed that there is no manufacturing process involved in making fibre from coconut husk and, therefore, the purchase value is not exigible to tax under the Act. This was negatived by the Sales Tax Officer who assessed the purchased turnover on coconut husk at 4 per cent. under S. 5A of the Act, which was confirmed by the appellate authority. On revision, the Sales Tax Appellate Tribunal by Order dated July 26, 1983 relying upon the decision of the Kerala High Court in Dy. Commissioner of Sales Tax (Law) v. Pie Food Packers, (1978) 41 STC 364: 1978 Tax LR 2104 (Ker), allowed the revision holding that no manufacturing process was