ISMAIL, C.J.

This is a petition to revise the order of the Tamil Nadu Sales Tax Appellate Tribunal, Additional Bench, Coimbatore, dated 20th December, 1978, made in T.A. No. 84 of 1978. The question considered by the Tribunal was a very short one. The petitioner herein entered into an agreement with Gwalior Rayons Silk Manufacturing Company Limited for selling certain quantities of approved firewood as per the specifications agreed to between the parties. The specifications agreed to between the parties have been extracted in the order of the Appellate Assistant Commissioner. The petitioner claimed that what was sold to Gwalior Rayons Silk Manufacturing Company Limited was only firewood and, therefore, was exempt from sales tax and that the fact the buyer utilised the same as raw material for the manufacture of rayon will not in any way alter the character of the goods sold by him. Having regard to the facts of this case, we are unable to accept this contention. Even though the agreement entered into between the parties describes the goods as "approved firewood", still the specification for the supply of the goods clearly indicate that neither party intended that the goo