JUDGMENT

Dipak Misra, J.

The appellant, M/s. M.P. Agencies, is a registered dealer under the Kerala Value Added Tax Act, 2003 (for brevity, ‘the 2003 Act’) and is a wholesale distributor for “Ujala Supreme” and “Ujala Stiff and Shine”, which are manufactured by M/s. Jyothy Laboratories Ltd. “Ujala Supreme” is a fabric whitener and “Ujala Stiff and Shine” is a liquid fabric stiffener. The product “Ujala Supreme” is described as fabric whitener for supreme whiteness of clothes, and “Ujala Stiff and Shine” is given the description, liquid fabric whitener for crisp and shining clothes.

2. As there was an issue relating to rate of tax applicable to the two products, the appellant filed an application for clarification before the Commissioner of Commercial Taxes, Thiruvananthapuram. The Commissioner vide order no. C7.34151/06/CT dated 25.10.2006 clarified the position which is in the nature of advance ruling by opining that the items “Ujala Supreme” and “Ujala Stiff and Shine” are commercially known as instant whiteners and the consumers who are purchasing the manufactured goods which a