BALASUBRAHMANYAN, J.

In this sales tax revision, the question is whether sale of eucalyptus trees is sale of firewood. If it is, it would be exempt from taxation.

Sale of firewood is exempted from sales tax under the Tamil Nadu General Sales Tax Act, 1959. The exemption is granted by the State Government in exercise of a power in that regard conferred by the statute. The order of exemption is notified in the Gazette under Notification No. II(1)/Rev/386(g)/74 dated 4th March, 1974. The notification simply says that the Governor is pleased to exempt from sales tax "firewood".

The claim for exemption under this notification arises in this way : The assessee is a forest coupe contractor. In a forest auction the assessee purchased eucalyptus and other trees as a coupe. He felled the eucalyptus trees and sold them to one P. R. Lakshmi, who is described as a pulpwood contractor. The eucalyptus trees purchased by her were then cut to X size and also debarked. The timber pieces so fashioned were sold by her to Gwalior Rayons, describing the pieces as "pulpwood". Gwalior Rayons used these shaven chips of eucalyptus wood as raw material to manufacture rayon in their mills.

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