D. J. JAGANNADHA RAJU, J. - This is a revision by the assessee against the order dated 18th April, 1989 in T.A. No. 1173 of 1987 on the file of the Sales Tax Appellate Tribunal, Additional Bench, Ernakulam. We are concerned with the assessment year 1982-83. The background in which the revision has been filed (briefly stated) is as follows : The revision-petitioner is a dealer in allopathic drugs, tarpaulin, etc. The petitioner, treating the tarpaulin as an unclassified item taxable at multi-point at 4 per cent, collected the tax at that rate from the customers and paid it to the Government. The assessment for the year 1982-83 was made treating tarpaulin as an unclassified item chargeable at 4 per cent. The assessment order was passed on 28th January, 1984. The Deputy Commissioner, Ernakulam, acting suo motu under section 35 of the Kerala General Sales Tax Act, 1963, invited objections of the petitioner, and then relying upon a clarification issued by the Government in G.O. (R) No. 60/86 TD dated 19th April, 1986, came to the conclusion that tarpaulin will come under entry 100 of the First Schedule to the Kerala General Sales Tax Act and it is taxable at 10 per cent with ef