Aravind Kumar, J.

The assessee is questioning the correctness and legality of the orders dated 17-10-2006 passed by the Karnataka Appellate Tribunal in S.T.A.Nos.547 and 548/2001 whereunder the orders of the Joint Commissioner of Commercial Taxes (Appeals) dated 23-4-2001 passed in No.KST.AP.419 and 420/1999-2000 dismissing the Asessee's appeals came to be confirmed by raising questions of law as enumerated herein below.

2. The facts leading to the filing of these two revision petitions are as follows:

(1) The Government of Karnataka issued a Notification Bearing No: FD 58 CSL 93(VI) dated: 31-3-1993 in exercise of its power conferred under Section 8-A of the Karnataka Sales Tax Act, 1957 (for short 'the Act') exempting the tax payable under Section 6 of the Act on the purchase of Raw-bathies consumed in the manufactured of Agarbatti in the State for sale. The said Notification reads as follows:

"In exercise of the powers conferred by Sec.8-A of the Karnataka Sales Tax Act, 1957 (Karnataka Act 25 of 1957), the Government of Karnataka hereby exempt with effect from the First day of April, 1993 –

(i) the tax payable by a manufacture of Agarbathi Under Section 6 of the