THOTTATHIL B. RADHAKRISHNAN, J.

1. These revisions under Section 41 of the Kerala General Sales Tax Act, 1963 and original petitions stand remitted by the Hon'ble Supreme Court of India as per the remand order dated 28.4.2011 in Civil Appeal No. 3758 of 2011 and connections.

2. The basic substratum of these litigations relates to the interpretation and construction of SRO No. 641 of 1981 and SRO No. 1516 of 1990 issued by the Government of Kerala in exercise of powers conferred under Section 10 of the KGST Act. As per SRO No. 641 of 1981 which is deemed to have come into force on 1.4.1981, reduced rate of tax was prescribed on the purchase of rubber by manufacturers of finished rubber projects within the State for use of such rubber by such manufacturers in the manufacture of finished rubber products within the State. Through SRO No. 1516 of 1990, the term finished rubber products occurring in SRO No. 641 of 1981 was sought to be explained by the introduction of an Explanation which is deemed to have come into force with effect from 1.4.1989 subject to the condition that taxes if any remitted by any dealer shall not be refunded. That Explanation is, inter alia, to the eff