C.N. Ramachandran Nair, J.

Question raised is whether the Sales Tax Appellate Tribunal was justified in declining exemption to the petitioner from tax payable under Section 5A of the KGST Act on purchase of rubber wood for use in manufacture of veneers. The benefit of exemption was claimed under Notification SRO No.403/94 dated 30.3.1994. The Notification produced before us shows that manufacturers of matches, packing cases, plywood, splints, tea chests, wooden crates, wooden cable drums or veneers, are granted exemption from payment of tax under Section 5A on purchase turnover of soft wood for manufacturing the items referred above. Petitioner accounted purchase of soft wood only at Rs.85,100/=. Therefore, the Assessing Officer treated that the balance purchase accounted from unregistered dealers is at Rs.9,88,435/=. Therefore, the Assessing Officer presumed that the balance unaccounted purchases from unregistered dealers represent purchase of rubber wood. Accordingly, he assessed the turnover under Section 5A of the KGST Act. The Officer, however, held that exemption under the Notification is not available for purchase of rubber wood. However, he has not recorded any f