JUDGMENT The judgment of the Court was delivered by V. V. KAMAT, J. - Although before the Tribunal two assessment years - 1987-88 and 1988-89 - were the concern, it is 1988-89 which is the subject-matter of this petition. The petitioner-assessee returned a taxable turnover of Rs. 2,92,23,990.60 for the year in question. The assessment was completed by the Sales Tax Officer. 2. This was challenged before the Appellate Assistant Commissioner, Trichur, on the ground that the assessee is eligible for reduction of tax payable on the sale of coconut oil cake to the extent tax was levied on the purchase turnover of copra by virtue of the Explanation to entry 51 of the First Schedule to the kerala General Sales Tax Act, 1963, from July 1, 1987. This contention was rejected and thereafter as a result thereof the matter was taken up before the Sales Tax Appellate Tribunal, Additional Bench, Palakkad. 3. It is necessary to highlight that the Agricultural Income-tax and Sales Tax Officer has observed in the following manner in the context : "In respect of 5 per cent local sale of coconut oil cake the tax leviable on the sale is reducible by the amount of tax on copra, out of which the cake is produced under entry at serial No. 51 of the First Schedule to the Kerala General Sales Tax Act, 1963, read with G.O. (P) 107/89/TD dated May 18, 1989. But the reduction in tax allowable is not worked out since there is full tax collection on such sales, which tax collection is payable to Government. The tax collection and tax reduction compensates, and hence it is not considered." It would be seen that an important aspect weighed is the load against the assessee that he had already collected the amount at the rate of 5 per cent in this connection. 4. It would be necessary to reproduce the statutory provision available from the entries in the First Schedule - Nos. 50 and 51 - which are in the following manner : THE FIRST SCHEDULE : ----------------------------------------------------------------- Serial Description of Point of levy Rate of tax No. goods (per cent) ----------------------------------------------------------------- 50 Coconut oil At the point of first sale 5 in the State by a dealer who is liable to tax under section 5. 51 Coconut oil Do. 5 cake ----------------------------------------------------------------- Explanation. 51 Coconut oil Do. 5 cake ----------------------------------------------------------------- Explanation. - Where a tax has been levied in respect of copra or coconut, the tax leviable on coconut oil and coconut oil cake, produced out of such coconut or copra shall be reduced by the amount of tax levied on such copra or coconut. It is also necessary to emphasise the specific contention of the petitioner that he is eligible for the reduction of tax due on the purchase turnover of copra only required for the production of coconut oil cake sold locally. The Tribunal has considered this contention describing it to be rather strange since the tax due on the purchase turnover of copra required for the production of coconut oil will be more than the tax on the sale of coconut oil cake even at the rate of 5 per cent, finding it evident that to treat the sale of coconut oil and coconut oil cake together for the purpose of granting reduction appearing to be the only intention with regard to the meaning of explanation to entry No. 51. 5. Reading the two entries along with the Explanation, as they are quoted hereinbefore, it would appear that the only way in which the Explanation can be understood would be that such reduction could not be considered in isolation, either with reference to coconut oil itself or with reference to coconut oil cake, depending on the choice of the assessee. The reason is simple that relationship between coconut oil, coconut oil cake and copra in regard thereto is to be understood on the basis of inter-connection thereof. 6. Although it is not possible to understand as to why the assessee is claiming, reduction of tax due on the purchase turnover of copra confining it only to coconut oil cake, it is not necessary in view of the situation of the use of conjunction "and" in the said explanation. Apart therefrom, the facet that is highlighted, as stated above by the trial authority regarding collection of the entire tax takes out the matter out of the province of "reduction". If the tax is collected by the dealer, it has to be remitted to the tax authority. In view of this aspect also, it is not possible to exercise powers under section 41 of the Kerala General Sales Tax Act, 1963. If the tax is collected by the dealer, it has to be remitted to the tax authority. In view of this aspect also, it is not possible to exercise powers under section 41 of the Kerala General Sales Tax Act, 1963. Accordingly the revision case stands dismissed and the orders of the lower authorities stands confirmed. Petition dismissed.