G. C. Bharuka, J.

( 1 ) THIS revision petition, filed under section 23 (1) of the Karnataka Sales Tax Act, 1957 (hereinafter, "the Act"), is directed against the order dated August 24, 1995 passed by the appellate Tribunal. By the said order, the Tribunal has confirmed the order of the Joint commissioner of Commercial Taxes upholding the provisional assessment orders passed by the assessing authority under section 12b (2) of the Act for the months of April to August, 1994. FACTS NOT IN DISPUTE

( 2 ) THE petitioner is a public limited company with registered office at Calcutta and corporate office at Bangalore. Sometime in 1991-92, it had set up a new industrial unit for blending and packaging of tea at the industrial area in Belur (Dharwad Growth Centre), Dharwad, by investing over Rs. 1. 6 crores in plant and machinery. The said unit commenced commercial production from May 6, 1993.

( 3 ) THE said unit of the petitioner-company was registered as a "new industrial unit" with the directorate of Commerce and Industries. The Joint Director (ID) of the Department of Industries and Commerce, Government of Karnataka, granted a certificate dated June 5, 1993, inter alia, certifying that

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