Judgment

RAMASWAMI,, J.

( 1 ) THIS appeal is brought by certificate from the judgment of the High court of Kerala dated 19/07/1965, in Tax Revision Case No. 8 of 1964.

( 2 ) THE respondent, the Midland Rubber and Produce Company Ltd. , hereinafter referred to as "the company", is a public limited company engaged in the business of planting and growing rubber trees and converting the latex obtained from the trees into rubber sheets and regularly selling the rubber sheets thus produced by them. The company is a registered dealer under section 7 of the central Sales Tax Act, 1956 (74 of of 1956), hereinafter referred to as "the Act". For the year 1961-62, the company returned in Form II an aggregate gross turnover of Rs. 11,43,140. 49 claiming exemption on the entire turnover. The company also filed C Forms covering an aggregate turnover of Rs. 11,03,934. 10. By his order dated 29/09/1962, the Sales Tax Officer, Special Circle, Alleppey, assessed the company on a net turnover of Rs. 11,04,268. 96.

( 3 ) THE company took the matter in appeal before the Appellate Assistant Commissioner of Agricultural Income-tax and Sales Tax, Trivandrum, and contended that though the company had sold rub