Basant, J.

Is the decision contemplated under Section 59A of the Kerala General Sales Tax Act an institutional decision or a personal one? Can the hearing under Section 59A be held by someone other than the Commissioner of commercial taxes and the decision be rendered by the Commissioner? These questions of importance arise for consideration in this appeal.

2. The fact scenario is simple. S.R.O.1729/93 deals with reduction in rate of tax to industrial units. Small, medium and large scale industries are eligible for certain concessions. This notification was later modified as per S.R.O.170/95. Clause 6A was added to the notification. We extract below the said clause 6A.

"6A. In the case of large scale industrial units started production after 23rd September 1991 and which purchase coconut or copra for producing coconut oil and coconut oil cake within the State, there shall be a reduction in respect of the tax payable by such units under the Kerala General Sales Tax Act, 1963 on the turnover of coconut or copra purchased and used for production of coconut oil and coconut oil cake from 3% to 1% for a period of seven years from the date of commencement of commercial productio