Ramachandran Nair,J.

This is an appeal filed under Section 62 of the Kerala Value Added Tax Act, 2003, hereinafter called the "Act" against Annexure 5 order issued by the Commissioner of Commercial Taxes under Section 94 of the Act, clarifying rate of tax on the products distributed by the appellant by name "Ujala Supreme" and "Ujala Stiff and Shine". The products are manufactured by M/s. Jyothy Laboratories, and appellant is the wholesale distributor of the products in Kerala. While Ujala Supreme is a fabric whitener, Ujala Stiff and Shine is a liquid fabric stiffner. The product samples produced by the appellant in bottles contain the description of the products as follows:

Ujala Supreme: Fabric Whitener- For Supreme Whiteness of Clothes.

Ujala Stiff and Shine: Liquid Fabric Whitener For Crisp & Shining Clothes.

When the appellant applied for clarification before the Commissioner of Commercial Taxes on the rate of tax applicable to the above two products, the Commissioner clarified that both the products would fall under Entry 27 of Notification, SRO 82/2006 dated 21.1.2006 issued under Section 6(1)(d) of the Act, which is as follows:

27. Detergents whether cake, liqu