JUDGMENT : S.C. Mohapatra, J. - This is an application under Article 226 of the Constitution of India by a Government company. 2. The petitioner claims to be carrying on mining operation of bauxites which is processed in a plant in Damanjodi in Koraput District for being used as raw material for the aluminium smelter plant at Angul. For the aforesaid business, the petitioner has captive power plants for generating electricity. The petitioner made application for including certain goods in its certificate of registration granted under the Central Sales Tax Act, 1956, as per Rules made thereunder. Sales Tax Officer included some of the items but did not include amongst others, computers and telecommunication and intercom equipments. No reason was indicated or intimated by the Sales Tax Officer to the petitioner as to why such goods were not included. Against such non-inclusion, the petitioner approached the Commissioner in revision u/s 23 of the Orissa Sales Tax Act. The Commissioner having rejected the revision, the same is assailed in the present writ application. 3. Mr. B.K. Mohanty, the learned counsel for the petitioner, submitted that the petitioner essentially requires the computers, intercom and telecommunication equipments to be included in the certificate of registration. To our question he clarified that the petitioner now does not require it for the period from 1982 till date and in case a direction is given for inclusion of the same now for the future use, the petitioner's requirement would be satisfied. 4. Application for inclusion in the certificate of registration was made in the year 1982 and revisional order was passed in 1983. Since then the writ application is pending in this Court. No useful purpose would be served by dealing with merit of such an application in the present writ application in view of the clarification given by Mr. Mohanty. 5. It is well-known that a machinery, equipment or other item of goods which might not have satisfied the conditions for inclusion in a certificate of registration, may become necessary at a later stage on account of advance in technology, research or for reducing the cost of ultimate production. Keeping the same in the background and the principle of inclusion in a certificate of registration as laid down by the Supreme Court, application is to be considered. Keeping the same in the background and the principle of inclusion in a certificate of registration as laid down by the Supreme Court, application is to be considered. It is not disputed that principle as laid down in [1965] 16 STC 563 (J.K. Cotton Spinning & Weaving Mills Co. Ltd. v. Sales Tax Officer) governs the field even now. In the said decision, the Supreme Court observed : "In our judgment if a process or activity is so integrally related to the ultimate manufacture of goods so that without that process or activity manufacture may, even if theoretically possible, be commercially inexpedient, goods intended for use in the process or activity as specified in Rule 13 will qualify for special treatment. This is not to say that every category of goods 'in connection with' manufacture of, or 'in relation to' manufacture, or which facilitates the conduct of the business of manufacture will be included within Rule 13. Attention in this connection may be invited to a judgment of this Court in which it was held that vehicles used by a company (which mined ore and turned out copper in carrying on activities as a miner and as a manufacturer) fell within Rule 13, even if the vehicles were used merely for removing ore from the mine to the factory, and finished goods from the factory to the place of storage. Spare parts and accessories required for the effective operation of those vehicles were also held to fall within Rule 13. See Indian Copper Corporation Limited Vs. Commissioner of Commercial Taxes, Bihar and Others, )." The aforesaid principle is to be applied to the facts and circumstances of each case. Where an application is not clear as to how such category of goods would be necessary to be included in the certificate of registration before finally deciding the question, the Sales Tax Officer ought to give an opportunity to the applicant for explaining the nature of use in connection with the manufacture or mining operation and in case explanation would not be clear without demonstration he may visit the spot within his jurisdiction to get a first-hand idea of the nature of use. When he visits the spot if requested by the applicant, he shall prepare a memorandum and keep the same on record. When he visits the spot if requested by the applicant, he shall prepare a memorandum and keep the same on record. Whether he includes the item or not, he should keep the reasons on record and in case of non-inclusion, furnish the reasons to the applicant when sought for, so that the same can usefully be used while assailing the same in higher statutory forums. 6. Since no useful purpose would be served in dealing with the revisional order on merit, we give liberty to the petitioner to make a fresh application to the Sales Tax Officer within March 15, 1990 and on receipt of such application, the Sales Tax Officer shall dispose of the same giving weight to the aforesaid observations on or before May 31, 1990. 7. In the result, writ application is disposed of with the aforesaid observations. No costs. V. Gopalaswamy, J. 8. I agree.