JUDGMENT The judgment of the court was delivered by UNNIKRISHNA KURUP, J. - The assessee-revision petitioner, Travancore Tea Estates Company Limited, is a company incorporated in Great Britain having its registered office in London and carrying on the business of tea planting in India at Vandiperiyar in Peermade Taluk in Kerala State. The assessee, who will hereinafter be referred to as the company, owns as many eight tea estates in Peermade Taluk, and to manufacture tea grown in those estates the company maintains separate tea factories in each of the said estates. On the application of the company, the sales tax authorities granted a sales tax registration certificate to the company on 9th January, 1963. Aggrieved by the non-inclusion of certain items of goods in the sales tax registration certificate the company filed O.P. No. 515 of 1963 on the file of this court and this court directed the Sales Tax Officer, Peermade, to decide the question of modification of the registration certificate, in the light of the decision of the Supreme Court in J.K. Cotton Spinning and Weaving Mills Co. Ltd. v. The Sales Tax Officer ([1965] 16 S.T.C. 563 (S.C.)] and Indian Copper Corporation Ltd. v. Commissioner of Commercial Taxes ([1965] 16 S.T.C. 259 (S.C.)]. The Sales Tax Officer allowed the inclusion of some of the items of goods claimed by the company in the registration certificate but refused to include the following items of goods in the tax registration certificate : (1) Fertilisers, chemicals, weedicides, insecticides, fungicides and pesticides for use in tea cultivation, (2) Cement and other building materials for installing and housing tea machinery and equipments, (3) Building materials, iron and hose-pipes and sanitary fittings for use in estates and estate factories. (4) Machinery, plant equipments, spraying and dusting machines, tools, implements, spare parts and accessories for use in tea estates, (5) Tools, implements and accessories for use in tea factories and estates. (6) Weighing and measuring and packing equipments for use in tea estates, and (7) All other articles and things for use in manufacture and processing for sale of tea. The company thereupon preferred on appeal before the Appellate Assistant Commissioner of Sales Tax, Kottayam, who partly allowed the appeal by directing the inclusion of items 4 and 5 in the certificate. The company thereupon preferred on appeal before the Appellate Assistant Commissioner of Sales Tax, Kottayam, who partly allowed the appeal by directing the inclusion of items 4 and 5 in the certificate. In a further appeal filed by the company before the Appellate Tribunal, the company urged that the remaining items were also eligible for inclusion in the registration certificate, but this plea was rejected by the Tribunal and the appeal dismissed. This revision is directed against the refusal of the Tribunal to include the following items in the sales tax registration certificate : (1) Fertilisers, chemicals, weedicides, insecticides, fungicides and pesticides for use in tea cultivation, (2) Cement and other building materials for installing and housing tea machinery and equipments, (3) Building materials, iron and hose-pipes and sanitary fittings for use in estates and estate factories, (4) Weighing and measuring and packing equipments for use in tea estates, and (5) All other articles and things for use in manufacture and processing for sale of tea. 2. It was urged by the learned counsel for the company that the business of the company was growing and manufacturing tea, that the growing of tea is an integral part of manufacture and that growing and manufacturing tea constitutes one integrated process. According to the learned counsel, the manufacture of tea commences from the stage of growing tea for producing green leaves and the Tribunal was, therefore, not justified in holding that the company is entitled to purchase at concessional rate of tax only such goods as are intended by him in the manufacture and processing of tea. The counsel relied on the ruling of the Supreme Court in J.K. Cotton Spinning and Weaving Mills Co. Ltd. v. The Sales Tax Officer ([1965] 16 S.T.C. 563 (S.C.)). 3. To fully appreciate the contention of the learned counsel for the company it is necessary to refer to the relevant provisions of the Central Sales Tax Act. Under section 6 of the Act, every dealer is liable to pay to the Central Government a tax under the Act on all sales effected by him in the course of inter-State trade or commerce during any year. Under section 6 of the Act, every dealer is liable to pay to the Central Government a tax under the Act on all sales effected by him in the course of inter-State trade or commerce during any year. Section 7 indicates the machinery set up for registration of dealers, while sub-section (1) of section 8 provides the rates of tax to be paid on the turnover by a dealer selling in the course of inter-State trade or commerce to a registered dealer goods of the description mentioned in sub-section (3). Sub-section (2) of section 8 prescribes the rates of tax payable by any dealer in any case not falling within sub-section (1) in respect of the sale by him of any goods in the course of inter-State trade or commerce. Sub-section (3) mentions that the goods referred to in clause (b) of sub-section (1) are goods of the class or classes specified in the certificate of registration of the registered dealer purchasing the goods as being intended for resale by him in the case of declared goods; and in the case of goods other than declared goods they are goods of the class or classes specified in the certificate of registration of the registered dealer purchasing the goods as being intended for resale by him or subject to any rules made by the Central Government in this behalf, for use by him in the manufacture or processing of goods for sale or in mining or in the generation or distribution of electricity or any other form of power. Section 13 authorises the Central Government to frame rules, inter alia, to enumerate the goods or class of goods used in the manufacture or processing of goods for sale or in mining or in the generation or distribution of electricity or any other form of power. 4. Section 13 authorises the Central Government to frame rules, inter alia, to enumerate the goods or class of goods used in the manufacture or processing of goods for sale or in mining or in the generation or distribution of electricity or any other form of power. 4. The Central Government has framed rules in exercise of the above power and rule 13, which is relevant for purposes of our discussion, is extracted below : "The goods referred to in clause (b) of sub-section (3) of section 8, which a registered dealer may purchase, shall be goods intended for use by him as raw materials, processing materials, machinery, plant, equipment, tools, stores, spare parts, accessories, fuel, or lubricants in the manufacture or processing of goods for sale or in mining, or in the generation or distribution of electricity or any other form of power." 5. The first item of goods sought to be included in the sales tax registration certificate, which was refused by the authorities below, is "fertilisers, chemicals, weedicides, insecticides, etc.", which are stated to be for use in the cultivation of tea leaves. According to the learned counsel for the company, the growing and manufacturing of tea constituted one integrated process and, therefore, the items of goods used for growing tea should be deemed to be goods intended for use "in the manufacture" of tea within the meaning of section 8(3)(b). This contention was negatived by the Tribunal as in its view "the Legislature has not included production by agriculture as one of the operations for which goods can be purchased under section 8 of the Central Sales Tax Act", and merely because agricultural process of the company is connected with the processing and manufacture, production of tea leaves do not form part of the manufacture and processing of tea. We are of the view that this reasoning of the Tribunal is not correct. In J.K. Cotton Spinning and Weaving Mills Co. Ltd. v. Sales Tax Officer ([1965] 16 S.T.C. 563 at 569 (S.C.)), it has been held that the expression "in the manufacture of goods" in section 8(3)(b) normally encompasses the entire process carried on by the dealer of converting raw materials into finished goods. In J.K. Cotton Spinning and Weaving Mills Co. Ltd. v. Sales Tax Officer ([1965] 16 S.T.C. 563 at 569 (S.C.)), it has been held that the expression "in the manufacture of goods" in section 8(3)(b) normally encompasses the entire process carried on by the dealer of converting raw materials into finished goods. Where any particular process is so integrally connected with the ultimate production of goods that, but for that process, manufacture or processing of goods would be commercially inexpedient, goods required in that process would fall within the expression "in the manufacture of goods". The expression "in the manufacture" takes in within its compass all processes which are directly related to the actual production. Green tea leave is a raw material for the manufacture of tea and the growing of tea leaves appears to us to be so integrally connected with the manufacture of tea that it can reasonably be taken as part of the process of manufacturing tea. As pointed out by the Supreme Court in J.K. Cotton Spinning and Weaving Mills Co. Ltd. v. Sales Tax Officer ([1965] 16 S.T.C. 563 at 569 (S.C.)) : "There is no warrant for limiting the meaning of the expression 'in the manufacture of goods' to the process of production of goods only. The expression 'in the manufacture' takes in within its compass, all processes which are directly related to the actual production." It may be that the tea leaves could be manufactured by a different agency and the company could use the leaves by purchasing it for the purpose of manufacturing tea. But in the affidavit filed on behalf of the company, it has been made clear that it would not be commercially expedient to leave the two processes to two different agencies and that the green tea leaf as soon as it has been plucked from the bush, had to be taken to the factory on the very same day to undergo the process of manufacture. In that view, the growing of green tea leaves and the manufacture of tea may constitute one continuous integrated process of manufacture. But this by itself is not sufficient to make the goods eligible for inclusion in the sales tax registration certificates. In that view, the growing of green tea leaves and the manufacture of tea may constitute one continuous integrated process of manufacture. But this by itself is not sufficient to make the goods eligible for inclusion in the sales tax registration certificates. Under rule 13 read with section 8(3)(b), the use of the goods in the manufacture or processing of goods for sale will not be a sufficient ground for inclusion in the certificate. The further requirement is that the goods must be for use as raw materials or processing materials or machinery, plant, equipment, tools, stores, spare parts, accessories, fuel or lubricants. The first item, namely, fertilisers, chemicals, insecticides, etc., in our opinion, cannot fall within the category of raw material or processing material or machinery, etc. The learned counsel for the company sought to contend that fertilisers, chemicals, etc., would come within the category of stores mentioned in section 8(3)(b) and that as such it is eligible for specification in the certificate. We are unable to agree with this submission. The word "stores" in the context in which it appears in rule 13 has to be necessarily goods intended for use in the manufacture or processing of goods for sale and it is not possible to hold that fertilisers, chemicals, weedicides, insecticides, etc., can come within the category. They are not in any way directly connected with the manufacturing or processing of tea. As pointed out earlier, the expression "in the manufacture" can take within its compass only processes which are directly related to the actual production. As such the claim for inclusion of this item in the sales tax registration certificate cannot be supported. 6. So far as items Nos. 2, 3 and 4 are concerned, the decision in J.K. Cotton Spinning and Weaving Mills Ltd. v. Sales Tax Officer ([1965] 16 S.T.C. 563 (S.C.)), makes it clear that building materials like lime and cement not required in the manufacture of goods for sale cannot be considered as raw materials in the manufacture or processing of goods. Weighing, measuring and packing equipments cannot also come within the scope of rule 13, since they are not intended for use in the manufacture of goods. Item No. 5, as noted by the Tribunal, is too vague and indefinite to deserve inclusion in the sales tax registration certificate. Weighing, measuring and packing equipments cannot also come within the scope of rule 13, since they are not intended for use in the manufacture of goods. Item No. 5, as noted by the Tribunal, is too vague and indefinite to deserve inclusion in the sales tax registration certificate. The view of the Tribunal that the above items are not eligible for inclusion in the sales tax registration certificate appears to be correct. The revision petition is, therefore, dismissed. But in the circumstances we make no order as to costs.