JUDGMENT K.S. PARIPOORNAN, J. These two revisions are filed by two different assessees. In both of them we are concerned with the assessment year 1978-79. The Revenue is the respondent in both the cases. The petitioners (assessees) are dealers in mats, mattings, etc. They are exporters in coir products. In pursuance of anterior contracts, the petitioners purchased coir products and after subjecting such coir products to sheaving, smoking and stencilling, exported them. Their claim for exemption under section 5(3) of the Central Sales Tax Act, 1956, was negatived by the assessing authority. The said view was upheld by the Sales Tax Appellate Tribunal. After referring to a few decisions, the Sales Tax Appellate Tribunal held that the unfinished goods purchased by the petitioners and those exported by them after the process, such as sheaving, smoking, stencilling, etc., are two different commodities and so, the goods exported by the petitioners are not the very same goods purchased and so, they are not entitled to the exemption pleaded under section 5(3) of the Central Sales Tax Act. The assessees have come up in revisions. 2. We heard counsel for the petitioner Mr. Abul Hassan, as also the counsel for the Revenue, Mr. N. N. D. Pillai. Counsel for the petitioners argued that the Appellate Tribunal laid undue stress on the decisions which dealt with the cases arising under the Central Excises and Salt Act, to determine as to whether there is a manufacturing process involved in subjecting the coir products purchased, to sheaving, smoking and stencilling before export. It was contended that the coir products purchased and the coir products exported are the same commercial commodity. It is erroneous to say that by the minimal process employed, such as sheaving, smoking, stencilling, etc., to make the commodity purchased, more attractive, the goods purchased become commercially a different product. On the other hand, counsel for the Revenue, Mr. Pillai, laid stress on the fact that a person, who wants to purchase the finished goods, after sheaving. smoking, webbing, stencilling, etc., will not be satisfied with the goods before such processes are employed, and that will show that the commodity purchased and the commodity exported after the above processes are distinct and different. In this view of the matter, counsel for the Revenue urged that the conditions prescribed under section 5(3) of the Central Sales Tax Act are not satisfied. 3. In this view of the matter, counsel for the Revenue urged that the conditions prescribed under section 5(3) of the Central Sales Tax Act are not satisfied. 3. On hearing the rival contentions of the parties, we are satisfied that the reasoning and conclusion of the Appellate Tribunal to negative the exemption pleaded by the petitioners, is clearly erroneous. The sole question, that arises for consideration, is whether, by the processes employed, the commodity purchased originally, can no longer be regarded as the original commodity, but instead, the product, recognised as a new and distinct commodity-distinct from the original-has come into being. The crucial test is whether in the eyes of those dealing in the commodity, or in the commercial parlance, the processed commodity is regarded as distinct in character and identity, from the original commodity. The decisions dealing with levy of excise duty cannot be a decisive factor in coming to the conclusion whether a commercially different commodity has emerged by the process employed by the dealer. In State of Tamil Nadu v. Pyare Lal Malhotra [1976] 37 STC 319 at page 326, the Supreme Court observed as follows : "It is true that the question whether, goods to be taxed have been subjected to a manufacturing process so as to produce a new marketable commodity, is th decisive test in determining whether an excise duty is leviable or not on certain goods. No doubt, in the law dealing with the sales tax, the taxable event is the sale and not the manufacture of goods. Nevertheless, if the question is whether a new commercial commodity has come into existence or not, so that is sale is a new taxable event, in the sales tax law, it may also become necessary to consider whether a manufacturing process, which has altered the identity of the commercial commodity, has taken place. The law of sales tax is also concerned with "goods" of various descriptions. The law of sales tax is also concerned with "goods" of various descriptions. It, therefore, becomes necessary to determine when they ceased to be goods of one taxable description and become those of a commercially different category and description." In Sterling Foods v. State of Karnataka [1986] 63 STC 239 (SC) at page 243, the question arose as to whether the purchase of shrimps, prawns and lobsters for fulfilling existing contract of export will continue to be the same commodity when the dealer processed them by cutting their heads and tails, peeling, deveining, cleaning and freezing them, before export. Holding that even after these processes the goods are commercially the same, the Supreme Court laid down the test in the following terms at page 243 : "It is in the context of these provisions of the Karnataka Act that we have to consider whether shrimps, prawns and lobsters, when subjected to the process of cutting of heads tails, peeling, deveining, cleaning and freezing, retain their original character and identity or become another distinct commodity. The test which has to be applied for the purpose of determining whether a commodity subjected to processing retains its original character and identity is as to whether the processed commodity is regarded in the trade by those who deal in it as distinct in identify from the original commodity or it is regarded, commercially and in the trade, the same as the original commodity. It is necessary to point out that it is not every processing that brings about change in the character and identity of a commodity. The nature and extent of processing may vary from one case to another and indeed there may be several stages of processing and perhaps different kinds of processing at each stage. With each process and suffered, the origial commodity experience chage. But it is only when the change or a series of changes take the commodity to the point where commercially it can no longer be regarded as the original commodity but instead is recognised as new and distinct commodity that it can be said that a new commodity, distinct from the original, has come into being. But it is only when the change or a series of changes take the commodity to the point where commercially it can no longer be regarded as the original commodity but instead is recognised as new and distinct commodity that it can be said that a new commodity, distinct from the original, has come into being. The test is whether in the eyes of those dealing in the commodity or in commercial parlance the processed commodity is regarded as distinct in character and identity from the original commodity : vide Deputy commissioner of Sales Tax (Law) v. Pio Food Packers [1980] 46 STC 63 (SC); [1980] 3 SCR 1271." The decision in Sterling Foods' case [1986] 63 STC 239 (SC), was followed in a later decision reported in Canara Exports v. State of Karnataka [1987] 66 STC 153 (SC). In the light of the principles laid down in the above decisions, we are of the view that the coir products purchased by the petitioners in pursuance to anterior contracts will not cease to be the same commodity and will not become a distinct and different commodity, merely because, the processes such as sheaving, smoking, webbing, stencilling, etc., are employed in order to make them more attractive or fit for export. In this view of the matter, we hold that the Appellate Tribunal was in error in holding that the goods exported by the petitioners are not the very same goods purchased, and so the petitioners are not entitled to the benefit of section 5(3) of the Central Sales Tax Act. The decisions rendered by the Appellate Tribunal in T.A. Nos. 890 of 1981 and 644 of 1982 are reversed. The concerned assessing authority will give appropriate relief to the petitioners with regard to the coir products exported by them under section 5(3) of the Central Sales Tax Act. 4. These tax revision cases are allowed. There shall be no order as to costs. Petitions allowed.