Radhakrishnan, J.

Petitioner is a private limited company engaged in the manufacture and sale of De-oiled cake, solvent extracted and refined oil. Company is a dealer on the roles of Additional Salestax Officer, II Circle, Palakkad.

2. Government of Kerala had issued SRO 1729/03 in exercised of the powers conferred by section 10 of the Kerala General Salestax Act, 1963 granting exemption to industrial units under medium and large scale industries and also small scale industrial units for a period of seven years from the date of commencement of commercial production in respect of tax payable under the Kerala General Salestax Act on the turnover of sale of goods manufactured and sold within the State. The company had started commercial production on 31-12-1996. Petitioner industry was also entitled to get the benefit of the said Government Order. On their application the Kerala State Industrial Development Corporation had issued eligibility certificate for salestax exemption equal to 100% of the fixed capital investment. On the basis of the eligibility certificate the Deputy Commissioner (General), Commercial Taxes, Thiruvananthapuram as per order No.C4.71164/97/CT dated 2-