ORDER G. C. BHARUKA, J. - The short question involved in the present case is as to whether the petitioner is entitled to claim exemption from the tax payable under the provisions of the Karnataka Sales Tax Act, 1957 (in short "the Act") on the retreading materials consumed in execution of the retreading contract of worn out old tyres in terms of the Notifications No. S.O. 931 dated June 8, 1989 and No. S.O. 1371 dated June 21, 1991 (hereinafter "the exempting notifications") issued under section 8A of the Act. 2. The petitioner-company herein is engaged in the business of retreading of tyres. It is registered as a dealer under the provisions of the Act. Its unit has been granted a certificate by the Directorate of Industries (annexure A) certifying it to be a registered small-scale industrial unit. It is aggrieved by the issuance of proposition notices pertaining to the periods 1990-91 and 1991-92 (annexures B and C) whereunder tax has been proposed to be levied in terms of section 5B of the Act in the relation to the transactions of the petitioner. 3. It has been stated by the petitioner that when a tyre casing is brought by the customer for the purpose of retreading in order to give it a fresh lease of life, it is subjected to various processes which are undertaken through different sophisticated machines. The processes involved are those of inspection, buffing, cementing, cushioning and ultimately wrapping the procured tread-strip through a tread builder. It is stated that through the process of heating the raw rubber strip (cushion) gets cured so that the tread, the cushion and the tyre are integrated together, thus completing the entire process. 4. Though for the present purposes, as I would be indicating hereinafter, it is not very essential to enter into the question whether the activities involved in the unit of the petitioner tantamounts to manufacturing or processing, but none-theless, as rightly brought to my notice by Sri Indra Kumar, learned counsel for the petitioner, the issue has been conclusively decided by the Supreme Court by holding that the retreading of old tyres does not amount to manufacturing process. It has been so held in the case of P. C. Cheriyan v. Mst. Barfi Devi reported in AIR 1980 SC 86 (para 10), as follows : "............ It has been so held in the case of P. C. Cheriyan v. Mst. Barfi Devi reported in AIR 1980 SC 86 (para 10), as follows : "............ The retreading of old tyres does not bring into being a commercially distinct or different entity. The old tyre retains its original character, or identity as a tyre. Retreading does not completely transform it into another commercial article, although it improves its performance and serviceability as a tyre. Retreading of old tyres is just like resoling of old shoes. Just as resoling of old shoes, does not produce a commercially different entity having a different identity, so from retreading no new or distinct article emerges. The old tyre retains its basic structure and identity." 5. The two exempting notifications referred to above for the present purposes are pari materia. Both the notifications have been issued under section 8A of the Act granting exemptions in respect of the goods manufactured and sold by tiny sectors and SSI units subject to fulfilment of other terms and conditions specified therein. The relevant part of the notification dated 8th June, 1989 reads as under : "In exercise of the powers conferred by clause (b) of sub-section (1) of section 8A of the Karnataka Sales Tax Act, 1957 (Karnataka Act 25 of 1957), the Government of Karnataka hereby exempts with immediate effect the tax payable under the said Act, in respect of the goods manufactured and sold by tiny sector and S.S.I. units mentioned in column 2 of the table below, located at places, subject to the ceilings and during the period indicated in the respective column Nos. 3,4, and 5 thereof : TABLE ................" 6. It can easily be seen from above that the language employed in the exempting notification to the extent it is relevant for present purposes, is absolutely clear and unambiguous. Going by its natural meaning, it provides for grant of exemption only in respect of goods manufactured and sold by the industrial units. As such it does not call for application of any interpretational aids, either internal or external, for the purpose of ascertaining any other purported scope and extent of the these notifications. 7. Going by its natural meaning, it provides for grant of exemption only in respect of goods manufactured and sold by the industrial units. As such it does not call for application of any interpretational aids, either internal or external, for the purpose of ascertaining any other purported scope and extent of the these notifications. 7. In the case of Polestar Electronic (Pvt.) Ltd. v. Additional Commissioner, Sales Tax, New Delhi [1978] 41 STC 409 (SC) at page 421; AIR 1978 SC 897 (para 7), it has been held thus : "Now, if there is one principle of interpretation more well-settled than any other, it is that a statutory enactment must ordinarily be construed according to the plain natural meaning of its language and that no words should be added, altered or modified unless it is plainly necessary to do so in order to prevent a provision from being unintelligible, absurd, unreasonable, unworkable or totally irreconcilable with the rest of the statute." 8. Despite the aforesaid well-settled principle, Mr. Indra Kumar submits that the right of a dealer to claim exemption as an SSI unit should be ascertained with reference to the industrial policy declared by the Government like the one contained in the G.O. dated September 5, 1988, in pursuance whereof the present statutory notifications were issued. A similar contention raised in the case of Lipton India Limited v. State of Karnataka [1994] 95 STC 225 has been rejected by this Court. While answering the first point as formulated in paragraph 24 of the judgment, it has been held that the policy as professed under the executive order even if it gives a wider coverage cannot take precedent over the statutory notification nor for that sake the latter need be broadly construed. Therefore this part of the submission raised on behalf of the petitioner cannot be accepted. 9. Admittedly the petitioner is engaged in the business of executing works contract. The tyre retreading has been included as item No. 24 under the Sixth Schedule to the Act. Section 5B of the Act provides for levy of tax on the taxable turnover of transfer of property in goods (whether as goods or in some other form) involved in the execution of works contracts mentioned in the said Schedule at the rates specified therein. Section 5B of the Act provides for levy of tax on the taxable turnover of transfer of property in goods (whether as goods or in some other form) involved in the execution of works contracts mentioned in the said Schedule at the rates specified therein. The constitutional validity of this legislative scheme envisaged by the Legislature for levying tax on deemed sales of goods consumed in execution of works contracts has been upheld by the Supreme Court in the case of Builders' Association of India v. State of Karnataka [1993] 88 STC 248. 10. It is also not in dispute that the goods like cushion (uncured rubber strips), cementing materials and precured tread strips, etc., which are used in the execution of retreading contract are neither manufactured nor sold as separate goods by the petitioner. Nonetheless because of the fiction created by insertion of clause (29A) in article 366 of the Constitution by 46th Constitution Amendment, read with the definition of "sale" under section 2(1)(t)(ii) of the Act, all such goods being involved in execution of the retreading contracts will be deemed to have been sold to the customers. In the said view of the matter, since petitioner has sold the retreading materials which had not been manufactured in its unit, it is not entitled to the benefits of the exemptions contemplated under the exempting notifications under consideration. 11. A similar view has been taken by a Division Bench of the Kerala High Court in A. Anthony Swamy v. State of Kerala [1994] 94 STC 477 thus : "8. We are of the view that even assuming that there is a manufacturing process involved in the retreading work and the retreaded tyre is a new article produced out of old tyre, the fundamental question is, whether the turnover, for which, exemption is sought, is of the goods produced and sold by the small-scale industrial unit ? It may be that the retreaded tyre is produced. But in the context and collocation of the words what is required is 'there should be sale of the goods produced'. It cannot admit of any doubt that in view of the amended provisions of the Constitution and the Act, there is a deemed sale of only the materials involved in the retreading and there is no sale of the retreaded tyre as such. It cannot admit of any doubt that in view of the amended provisions of the Constitution and the Act, there is a deemed sale of only the materials involved in the retreading and there is no sale of the retreaded tyre as such. In this perspective, it cannot be stated that there is sale of the goods produced. There is no sale of the retreaded tyre. Unless there is a sale of the goods produced, the small-scale industrial unit will not be entitled to the exemption relied on." 12. Writ petition is accordingly dismissed. Anyhow, as prayed, liberty is granted to the petitioner to file objections in response to the impugned proposition notices within four weeks from today, which, if so filed, shall be duly considered by the assessing officer while passing assessment orders. There will be no order as to cost. Writ petition dismissed.