K. S. PARIPOORNAN, J. - These are connected cases. The same assessee is the revision-petitioner in both these revisions. The petitioner is a company carrying on the business of manufacture of automobile tyres, tubes, etc., at Modinagar with the branch office at Ernakulam. One of the products sold by it is rubber flaps. It is stated to be a sheet of rubber used for placing between the metal rim of the wheel and the rubber tube inside the tyre of a motor vehicle so as to give better protection to the tube from damage. These flaps are usually used for heavy vehicles. We are concerned with the assessment years 1982-83 and 1983-84. Originally, the assessment were made treating the rubber flaps manufactured and sold by the revision-petitioner as a rubber product coming within entry 39 of the First Schedule to the Kerala General Sales Tax Act, 1963 ("the KGST Act"), viz., "rubber products other than those specifically mentioned in the Schedule". It was so taxed at the point of first sale at the hands of the dealer at 8 per cent. It is seen that the Deputy Commissioner of Sales Tax initiated suo motu revision, for both the years, under section 35 of the KGST Act and took the view