Ramachandran Nair, J.

The question raised in the revision filed by the assessee is whether the Tribunal was justified in confirming disallowance of exemption claimed on the purchase tax payable under Section 5A of the KGST Act on paddy under SRO 1729/93. The petitioner started a rice mill in 1998 and being a new small scale industrial unit, petitioner is entitled to sales tax exemption on the rice and other products manufactured and sold under notification SRO 1729/93 for a period of seven years. Besides the exemption available to manufactured goods sold by the new small scale industrial units, such units are also granted exemption under the same notification in respect of tax payable on goods taxable at the point of last purchase in the State. Admittedly, petitioner is granted sales tax exemption on products namely, rice, bran etc. The petitioner purchased paddy from unregistered dealers who are not liable to pay sales tax on their sales turnover of paddy by virtue of being agriculturists. Since goods purchased namely, paddy, is taxable under Entry 9 of the Second Schedule to the KGST Act and since the commodity has not suffered tax at the point of sale in the State, th