Judgment :- The factory belonging to the petitioner and situated at Alleppey is a Small Scale Industrial Unit (Vide Ext.Pl). Rubberized coir is manufactured there. Rubber latex is one of the raw materials used for manufacturing rubberized coir. How this product is manufactured is succinctly stated in Para 2 of the O.P., which is extracted hereunder "The process of manufacture of rubberized coir consists in unlearning curled coir to obtain loose fibers which are spread on to an automatic sheet plant and natural rubber is sprayed on both sides. Thereafter the combination of coir fiber and rubber is dried in a drier and a number of layers and the said sheets (known as fleeces) are pressed together to obtain the required thickness of rubberized coir product. The main raw materials for the said products are curled coir and rubber (latex)". 2. The rubber purchased by the petitioner as raw material is liable to be taxed under entry 161 of Schedule I of the Kerala General Sales Tax Act, for short The Act at the rate of 6%. 3. The petitioner however, is entitled to the benefit of the Notification, S.R.O.585/80 and as such they can be made liable to pay tax only at the reduced rate of 3%, the counsel submits. The assessing authority, on the other hand, contends that the petitioner is not entitled to the benefit of this Notification because his product cannot be said to be a rubber product, although it is a Small Scale Unit, recognized by the Department of Industry. 4. The question thus arising for consideration is: Is the petitioner entitled to the benefit of the Notification although it cannot be said to be a Small Scale Registered Industrial unit manufacturing rubber product? The answer depends upon the construction of the Notification. I shall now read' the Notification: - "S.r.o.585/80 hereby make a reduction in the rate of tax payable under the said Act On the purchase of rubber by the Small Scale Rubber Industrial Units within the State for use of such rubber by such units in the manufacture of rubber products within the State from 5 percent o 3 per cent". The plain and unambiguous language used in this Notification no doubt, would suggest that the Small Scale Unit which can claim the concession shall be a Small Scale Registered Industrial Unit manufacturing rubber products. The plain and unambiguous language used in this Notification no doubt, would suggest that the Small Scale Unit which can claim the concession shall be a Small Scale Registered Industrial Unit manufacturing rubber products. This Notification however, has an Explanation and it reads: - "For the purposes of this Notification, small scale Rubber Industrial Unit means, any small scale industrial unit registered as such either provisionally or permanently with the Department of Industries and Commerce and utilizing rubber in any form as one of the raw materials for the industrial unit". This explanation to my mind defines "a small scale rubber industrial unit" and going by this definition, a small scale industrial unit registered as such either provisionally or permanently with the Department of Industries and Commerce also can claim the benefit of this Notification provided the said unit is utilizing rubber in any form as one of the raw materials for the industrial unit. The Explanation thus reflects the intention of the Government to extend the concess ion given to small scale rubber industrial units to other small scale industrial units registered as such either provisionally or permanently with the Department of Industries and Commerce and utilizing rubber as one of the raw materials for the manufacture of its product. 5. Having understood the meaning of this Notification thus, we shall see whether the petitioner is entitled to the benefit of the Notification. That the petitioner is a small-scale unit using rubber latex as one of the raw materials for the manufacture of its products is beyond dispute. The unit thus satisfies the requirements prescribed under the Explanation and as such entitled to enjoy the concession given to small-scale rubber industrial units, by the Notification. There will therefore be a declaration that the petitioner is liable to pay purchase tax on the rubber latex it purchased for the manufacture of their products, only at the reduced rate of 3%. The O.P. accordingly is allowed. No costs.