JUDGMENT K. S. PARIPOORNAN, J. - The revision petitioner is an assessee under the Kerala General Sales Tax Act. The respondent is the Revenue. We are concerned with the assessment year 1980-81. 2. The short question that falls for consideration is whether the assessee is entitled to the exemption provided by S.R.O. No. 968/80 on the turnover of plain envelopes, craft envelopes and calico mounted colour papers. For the year 1980-81, the assessee furnished a taxable turnover of Rs. 8,89,661.88. The assessing authority determined the taxable turnover at Rs. 72,15,400. The total sales a per accounts were Rs. 1,06,61,758.95. The assessing authority initially granted exemption pleaded by the assessee, which covered the turnover relating to plain envelopes, craft envelopes and calico mounted colour papers. The Deputy Commissioner of Sales Tax initiated suo motu revision proceedings under section 35 of the Act and by order dated November 16, 1988, he held that the assessment order passed by the assessing authority for the year 1980-81 dated February 28, 1985, is clearly erroneous and that exemption in respect of goods not covered by the certificate of registration should not have been granted in terms of S.R.O. No. 968/80 and so he set aside the order of assessment and ordered a remit. The Sales Tax Officer was directed to dispose of the matter afresh according to law. The revision petitioner-assessee assailed the aforesaid suo motu order passed in revision by the Deputy Commissioner of Sales Tax by filing an appeal before the Sales Tax Appellate Tribunal. The Appellate Tribunal by order dated May 29, 1989, held that the claim for exemption for plain envelopes, craft envelopes and calico mounted colours papers are not covered by the certificate of registration and so exemption under S.R.O. No. 968/80 cannot be granted on the turnover of the said items and concurred with the decision of the Deputy Commissioner of Sales Tax. The turnover of the said three items as given in the order of the Deputy Commissioner of Sales Tax is as follows : ------------------------------------------------------------------------ "Serial Name of the Delivery note No. Period Amount No. item ------------------------------------------------------------------------ 1. Plain envelops 143601 July, 1980 Rs. 3,16,500 143602 143603 2. Craft envelopes 143604 August, Rs. 9,17,256 143614 1980 January, 1981 3. Calico mounted 143615 to 143625 November, Rs. 26,66,945 colour papers. except D/N 1980 and Nos. 143617, January, 143621 and 1981 143624. -------------- Total.... Rs. Plain envelops 143601 July, 1980 Rs. 3,16,500 143602 143603 2. Craft envelopes 143604 August, Rs. 9,17,256 143614 1980 January, 1981 3. Calico mounted 143615 to 143625 November, Rs. 26,66,945 colour papers. except D/N 1980 and Nos. 143617, January, 143621 and 1981 143624. -------------- Total.... Rs. 39,00,701" -------------- It is thereafter the assessee has come up in revision to this Court assailing the order of the Sales Tax Appellate Tribunal, dated May 29, 1989. 3. We heard counsel for the revision petitioner and also counsel for the respondent-Revenue. It will be useful to extract S.R.O. No. 968/80 : "S.R.O. No. 968/80.......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 per cent of the cumulative gross fixed capital investment of the unit. Explanation (1). - 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 reopened under a new banner and style of business, after 1st April, 1979. Explanation (2). - In computing the fixed capital investments, second-hand machinery and equipments procured from within the State of Kerala shall not be considered for sales tax concession. This notification shall be deemed to have come into force with effect from 1st April, 1979. (G.O. Ms. Explanation (2). - In computing the fixed capital investments, second-hand machinery and equipments procured from within the State of Kerala shall not be considered for sales tax concession. This notification shall be deemed to have come into force with effect from 1st April, 1979. (G.O. Ms. No. 74/80/TD) dated September 29, 1980 in Kerala Gazette No. 42 dated October 21, 1980)." Counsel for the assessee produced before us the registration certificate given to the assessee as a small-scale industrial unit. The registration number is "09 09 02625/79/PMT/SSI" dated "December 31, 1979". The certificate specifies that the assessee is a small-scale industrial unit registered with the General Manager, District Industries Centre, Trichur, and is allowed the above registration number for the factory located at Talapilly Taluk, Kunnamkulam Municipality for the following manufacturing/processing/servicing activity. Products manufactured : 1. Card board boxes, calendars, playing cards, job works and note books. 2. Raw materials : Spirit, binding cloth, photofilms, zinc sheets, damping house, paper, board, printing ink, tin sheets, stitching wire and paraffin wax. The relevant certificate number is "R-6705/81" "R-14361/79/K.Dis". It is agreed that the certificate of registration does not mention that the assessee is entitled to manufacture or produce plain envelopes, craft envelopes and calico mounted colours papers. But counsel for the revision petitioner highlighted the order passed by the General Manager, District Industries Centre, Trichur, dated January 4, 1985 wherein he has stated that the unit is eligible for exemption from sales tax under the Government Order - G.O. Ms. No. 74/80/TD dated September 29, 1980 - for the following items manufactured and sold by it for the period from November 26, 1979 to November 25, 1984 : Sl. No. Name of items Quantity per annum 1. Card board boxes 25 lakhs Nos. 2. Note books 40 tons 3. Other printed items 120 tons 4. Job work 100 tons It was contended that item No. 3 "other printed items," specified in annexure I, proceedings of the General Manager, District Industries Centre, Trichur dated January 4, 1985, will take within its fold the turnover relating to plain envelopes, craft envelopes, calico mounted colour papers, and so the assessee is entitled to the exemption on the turnover relating to these items also. We are unable to accept the above plea. As per S.R.O. No. 968/80 - G.O. Ms. We are unable to accept the above plea. As per S.R.O. No. 968/80 - G.O. Ms. No. 74/80/TD dated September 29, 1980 - a dealer is entitled to an exemption as provided, 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 5 years. In order to enable such units to avail the exemption, the units should produce the proceedings of the General Manager of the District Industries Centre declaring eligibility for claiming exemption. The said notification itself has stated that new industrial units under the small-scale industries shall mean undertakings set up on or after April 1, 1979 and registered with the Department of Industries and Commerce as a small-scale industrial unit. It is clear from a perusal of the notification aforesaid that though the exemption is available in respect of the turnover of the sale of goods produced and sold by a new industrial unit under the small-scale industries, the new industrial unit should be one set up after April 1, 1979 and registered with the Department of Industries and Commerce as a small-scale industrial unit. It is not every new industrial unit that will be entitled to the exemption. It is only such of those units which are set up on or after April 1, 1979 and registered with the Department of Industries and Commerce as a small-scale industrial unit, that will be entitled to the exemption provided by the notification. In order to prove eligibility the proceedings of the General Manager, District Industries Centre declaring eligibility of the unit should be produced, but the fundamental thing to be proved is that the new industrial unit was set up on or after April 1, 1979 and registered with the Department of Industries and Commerce as a small-scale industrial unit. It is evident that the registration of the unit with the Department of Industries and Commerce as a small-scale industrial unit is a condition precedent to avail the exemption. It is only those units as registered with the Department of Industries and Commerce as a small-scale industries unit, that will be entitled to the exemption. The certificate of registration granted to the unit in the instant case is dated December 31, 1979. It is only those units as registered with the Department of Industries and Commerce as a small-scale industries unit, that will be entitled to the exemption. The certificate of registration granted to the unit in the instant case is dated December 31, 1979. The registration certificate, shows that "the assessee" has been permitted to manufacture/process/carry service activities only in certain specified goods. The certificate granted admittedly does not take in manufacture of plain envelopes, craft envelopes and calico mounted colour papers; nor does the certificate aforesaid refer to other printed items mentioned in annexure I - proceedings of the General Manager, District Industries Centre, dated January 4, 1985. The mere fact that in the proceedings of the General Manager, District Industries Centre, dated January 4, 1985, it is mentioned that the assessee is also entitled to exemption on other printed items is of no consequence or relevance in considering as to whether the assessee is entitled to the exemption provided by S.R.O. No. 968/80. We are of the view, that the exemption provided by S.R.O. No. 968/80 is not and cannot be made available to the revision petitioner-assessee, since the registration certificate granted to the revision-petitioner (assessee) does not cover production of these items - plain envelopes, craft envelopes and calico mounted colour papers. The Deputy Commissioner of Sales Tax, as also the Sales Tax Appellate Tribunal were justified in negativing the plea of exemption for the said three items which are not covered by the certificate of registration. 4. There is no merit in this revision. The revision is without merit. It is dismissed. Petition dismissed.