JUDGMENT K.S. PARIPOORNAN, J. These 29 revisions are filed by the State of Kerala. The respondents are cashew dealers. They are assessees under the Kerala General Sales Tax Adt, 1963. It is common ground that all the assessments, which are the subject-matter of dispute in these revisions, relate to assessment years prior to 1974. While effecting assessments of the respondents (assessees), the assessing authority included the proceeds of discarded items like empty tins, cashew shells and gunnies, to the taxable turnover. The objection of the respondents that they are not dealers in these items and so the turnover under these items are not includible in the taxable turnover, was negatived by the assessing authority, as well as by the first appellate authority. The Sales Tax Appellate Tribunal, placing reliance on the decision of this Court reported in Deputy Commissioner of Sales Tax v. Carborundum Universal Ltd. [1981] 47 STC 73 held that for the turnover relating to discarded items like empty tins, cashew shells, gunnies, etc., the assessees should be given exemption. The Revenue has come up in revisions from the orders passed in second appeals by the Sales Tax Appellate Tribunal. 2. We heard counsel for the Revenue, Mr. T. Karunakaran Nambiar and also counsel for the respondents, Mr. Arikkat Vijayan Menon. Counsel appearing on both sides agreed that the sole question involved in all these revisions is whether the respondent's turnover relating to the discarded items, like cashew shells, gunnies and empty tins, is exigible to sales tax under the Kerala General Sales Tax Act. The answer to the question will depend upon the fact as to whether the respondents can be considered to be dealers under the Kerala General Sales Tax Act as regards the said items. Section 2(viii) of the Kerala General Sales Tax Act defining the word "dealer" and section 2(vi) of the Kerala General Sales Tax Act defining the word "business" as they existed before the amendment made, by Act 22 of 1974, are relevant in this regard. Under section 5 of the Act it is only the taxable turnover of a dealer over a particular limit, that is brought to tax. Under section 5 of the Act it is only the taxable turnover of a dealer over a particular limit, that is brought to tax. Section 2(viii) and (vi), before the amendment by Act 22 of 1974 was as follows : "(viii) 'dealer' means any person who carries on the business of buying, selling, supplying or distributing goods, directly or otherwise, whether for cash or for deferred payment, or for commission, remuneration or other valuable consideration and includes -" "(vi) 'business' includes any trade, commerce or manufacture or any adventure or concern in the nature of trade, commerce or manufacture, with or without profit-motive in such trade, commerce, manufacture, adventure or concern." By Act 22 of 1974, the definition of the word "business" was recast as follows : "(vi) 'business' includes, - (a) any trade, commerce or manufacture or any adventure or concern in the nature of trade, commerce, or manufacture, whether or not such trade, commerce, manufacture, adventure or concern is carried on with a motive to make gain or profit and whether or not any profit accrues from such trade, commerce, manufacture adventure or concern; and (b) any transaction in connection with, or incidental or ancillary to such trade, commerce, manufacture, adventure or concern." 3. As stated earlier, we are concerned with the definition of the words "dealer' and "business" before 1974. In Carborundum Universal Ltd.'s case [1981] 47 STC 73 (Ker) the assessee was a dealer in synthetic abrasive grains. Its sales turnover of scrap materials, such as old gunnies, old drums, polythene bags, bottles, tins, etc., were sought to he included in the taxable turnover. This Court referred to the definition of the word "business" before and after the amendment by Act 22 of 1974, as also the definition of the word "dealer" and in view of the decisions of the Supreme Court in State of Gujarat v. Raipur Manufacturing Co. Ltd. [1967] 19 STC 1 and State of Tamil Nadu v. Burmah Shell Oil Storage and Distributing Co. of India Ltd. [1973] 31 STC 426 held that the assessee in the said case is not a dealer in respect of the articles forming the subject-matter of the disputed turnover and the sale proceeds of such articles cannot be included in the taxable turnover of the assessee. of India Ltd. [1973] 31 STC 426 held that the assessee in the said case is not a dealer in respect of the articles forming the subject-matter of the disputed turnover and the sale proceeds of such articles cannot be included in the taxable turnover of the assessee. This Court held that in the earlier decisions of this Court in Deputy Commissioner of Agricultural Income-tax and Sales Tax v. Kottamullai Tea Co. Ltd. [1975] 36 STC 499 (App.) and Deputy Commissioner of Agricultural Income-tax and Sales Tax v. Balakrishna Pillai [1975] 36 STC 487, no reference was made to the decision of the Supreme Court in Burmah Shell's case [1973] 31 STC 426 and so no reliance can be placed on the said earlier decisions. It is common ground that if the decision of this Court in Carborundum Universal Ltd.'s case [1981] 47 STC 73 lays down the correct law, the Appellate Tribunal was justified in holding that the respondents are entitled to exemption on the turnover relating to empty tins, cashew shells and gunnies. Counsel for the Revenue contended that the decision in Carborundum Universal Ltd.'s case [1981] 47 STC 73 (Ker) requires reconsideration. Having bestowed our anxious thought in the matter, we are of the view that the decision of this Court in Carborundum Universal Ltd.'s case [1981] 47 STC 73 is in accord with the principles laid down by the Supreme Court in Raipur Manufacturing Co. Ltd.'s case [1967] 19 STC 1 and the Burmah Shell Oil Storage and Distributing Co.'s case [1973] 31 STC 426, and so, in our view, reconsideration of the decision of the Carborundum Universal Ltd.'s case [1981] 47 STC 73 (Ker) is not warranted. In the light of the above, we hold that the Appellate Tribunal was justified in these cases in holding that the respondents (assessees) are entitled to exemption for the turnover relating to the discarded items like gunnies, cashew shells, empty tins, etc. The decisions rendered by the Appellate Tribunal in all these cases do not call for any interference. These revisions are without merit. They are dismissed. No costs. Petitions dismissed.