Judgment :- 1. This revision under S.41 of the Kerala General Sales Tax Act, 1963 (the Act in brief), is at the instance of the Revenue and relates to the assessment made on the respondent under the Act for the assessment year 1981-82. The assessee is running an oil mill by name Afra Oil Mill at Payanagadi in Cannanore District, which he has taken on lease from one Smt. C. P. Abeeda. The oil mill in question is a "new industrial unit under the small scale industries" set up after 1-4-1979 and hence coming within the purview of notification SRO. No. 968/80 issued by the Government of Kerala in exercise of the powers vested in them under S.10 of the Act. The assessee claimed exemption from payment of sales tax in respect of the sale of the coconut oil and oil cake produced by him in the mill, as under the abovementioned notification. The assessing authority repelled this claim for exemption for two reasons, namely that the assessee did not produce the proceedings of the General Manager, District Industries Centre declaring the eligibility of the unit for exemption and that the assessee was running the oil mill only as a lessee from C. P. Abeeda and as such was not entitled to exemption as he bad no investment on fixed capital in the unit. Before the first appellate authority the assessee produced the requisite proceedings of the General Manager of the District Industries Centre regarding the eligibility of the unit for exemption from sales tax. The first Appellate Authority however, held that the assessee, being only a lessee and not the owner, the benefit of the exemption under the notification aforesaid was not available to him. 2. The assessee took up the matter in second appeal. The Tribunal accepted the assessee's claim for exemption stating that there was no stipulation under the notification that the owner of the unit alone will be entitled to the exemption and that in view of the proceedings of the General Manager, District Industries Centre, Cannanore, the assessee was entitled to exemption in respect of the goods produced in the Afra Oil Mill and sold by him. The appeal was thus allowed and the revision is filed therefrom. 3. Sri. The appeal was thus allowed and the revision is filed therefrom. 3. Sri. T. Karunakaran Nambiar, counsel for the Revenue strenuously contends that the exemption under the notification is available only to the owner of the unit, who has invested funds for the setting up of the unit and to none else. We shall examine this contention. 4. The notification SRO. No. 968/80 is in these terms: - In exercise of the powers conferred by S.10 of the Kerala General Sales Tax Act. 1963 (15 of 1963), the Government of Kerala, having considered it necessary in the public interest so to do, hereby make an exemption in respect of the tax payable under the said Act on the turnover of the sale of goods produced and sold by the New Industrial Units under the Small Scale Industries for a period of five years from the date of commencement of sale of such goods by the said units subject to the conditions that the tax if any collected by such units by way of tax on their sales shall be paid over to Government and that sales-tax, if any, already paid by such units to Government shall not be refunded: Provided that such units shall produce proceedings of the General Manager, District Industries Centre declaring the eligibility of the units for claiming exemption from sales tax: Provided further that the cumulative sales tax concession granted to a unit at any point of time within this period shall not exceed 90% of the cumulative gross of fixed capital investment of the unit. Explanation: For the purpose of this notification "New Industrial Units under the Small Scale Industries" shall mean Undertakings set up on or after 1st April, 1979, and registered with the Department of Industries and Commerce as a small-scale industrial unit, but shall not include old industrial units under the Small Scale Industries closed down and re-opened under a new banner and style of business, after 1st April, 1979." The necessary condition for the earning of the exemption under this notification is that the goods, the sale of which is sought to be exempted from tax should be produced and sold by the industrial unit as defined in the explanation to the notification, of course, subject to the other conditions specified in that notification. The exemption under the notification is to goods produced and sold by the unit. The exemption under the notification is to goods produced and sold by the unit. S.10 of the Act under which the notification is issued empowers the Government to make an exemption in respect of any tax payable under the Act either on the sale or purchase of any specified goods or class of goods or by any specified class of persons in regard to the whole or any part of their turnover. The exemption under the notification in question is one which falls under the first category mentioned above. The eligibility for exemption is related to the question whether the goods are produced and sold by a "new Industrial Unit" as defined in the Explanation. The notification does not on its terms confine the exemption to the owner of the unit who has invested money for its being set up, as the first two authorities would have it to be. The exemption is extended to all goods produced and sold by the unit A person running the industrial unit, whether as owner or as lessee or even as a licensee having complete control over the unit is entitled to the exemption so long as the goods are produced in the unit and sold by him. We do not find in the notification any words of limitation, delimiting its scope and applicability to persons who are owners in the strict sense of the term. 5. Counsel for the revenue apprehended that there was a likelihood of both the owner and the lessee separately claiming exemption upto the limit prescribed. We do not find any justification for this apprehension. The total amount of concession granted to a unit is limited to 90 per cent of the cumulative gross of the fixed capita) investment of the unit, as per the second proviso to the notification. There is, therefore, no scope for the cumulative exemption granted in respect of those running the unit exceeding this amount. 6. There is no dispute that the assessee was a person running the oil mill as lessee, or that the goods sold by him in regard to which exemption was claimed were not produced in the oil mill. If so there is no merit in the contentions raised by the Revenue. We dismiss the tax revision case.