( 1 ) THIS revision has been filed by M/s. Kishan Krishi Yantra Udyog, Kanpur, and pertains to the assessment year 1975-76.

( 2 ) THE assessee carries on the business of manufacture and sale of paddy dehusker, rice polisher, winnower and other agricultural implements. The assessee has claimed exemption from sales tax for his sales of paddy dehusker, rice polisher amounting to Rs. 48,965 in view of Notification no. ST-2783/x- 902 (60)-59 dated 1st June, 1963, as amended by Notification No. ST-351/x902 (60)-59 dated 5th February, 1968. The exemption was claimed on the ground that the assessee-firm was manufacturing goods for Khadi and Village Industries Commission, Bombay, for the manufacture of paddy dehusker, rice polisher and grader-cum-winnower. It also claimed that its sale of winnower, the trade name of which was ghuria chalna, was manually operated and was an agricultural implement.

( 3 ) THE Sales Tax Officer declined to give exemption to the assessee. The assessee appealed. In appeal the assessee was unsuccessful in this regard. The Sales Tax Tribunal also denied exemption which was in respect of the sales of the aforesaid commodities.

( 4 ) THE Sales Tax Tri