Judgment :- Mohammed, J. The writ petitioner is a Company known as 'the Cochin Malabar Estates and Industries Limited.' (hereinafter, referred to as 'the assessed). The assessee is a registered dealer under the provisions of Central Sales tax Act, 1956 (for short, the act). It had obtained the certificate of registration under S.7(3) of the Act. The challenge is against the deletion of certain goods specified in the certificate of registration. Exts. P1, P2 and P4 orders passed by the respondents are sought to be quashed in this writ petition. There is a further prayer for a direction to the respondents to re-specify the goods deleted in the certificate of registration granted to the assessee. 2. By Ext. P1 the first respondent, the Assistant Commissioner of Sales Tax (Assmt.) found that the assessee had issued C forms for the purchase of certain goods other than those specified in the certificate of registration. Consequently all the items other than those permitted under the Act and Rules were deleted and the assessee had been restrained from purchasing such items. According to the first respondent, the assessee 's business is solely the sale of rubber produced in the estate, and hence, the purchases of Bitumen compound, Alkathine fibre and PVC-APVC by issuing C forms are unauthorised. As against the said order, the assessee filed revision petition before the second respondent, Deputy Commissioner, who by Ext. P2 order found that the goods in question, are not for use in the manufacture or resale. Being dissatisfied with Ext. P2 order of the second respondent upholding Ext. P1 the assessee filed a further revision before the third respondent, Board of Revenue. However, by Ext. P4 order third respondent confirmed the orders of the assessing authority as well as the first revisional authority. 3. S.7 of the Act deals with the registration of dealers under the Act and issue of certificate of registration under sub-s.(3) therein. While issuing the certificate, the authority before whom application for registration is filed shall specify the class or classes of goods for the purpose of sub-s.(1) of S.8, which prescribes the rate of tax on sales in the course of inter-state trade and commerce. While issuing the certificate, the authority before whom application for registration is filed shall specify the class or classes of goods for the purpose of sub-s.(1) of S.8, which prescribes the rate of tax on sales in the course of inter-state trade and commerce. Under sub-s.(1)(b) every dealer who in the course of inter-state trade and commerce sells to a registered dealer other than the Government, goods of the description referred to in sub-s.(3) shall be liable to pay tax at the rate of 4 % of his turnover. This concessional rate of tax is applicable only in respect of goods specified in the certificate of registration. 4. Sub-s.(3) of S.8 in so far as it is relevant in the present context is as follows: (3) The goods referred to in clause (b) of sub-s.(1) -(a) (b) are goods of the class of classes specified in the certificate of the registration of the registered dealer purchasing the goods as being intended for resale by him or subject to any rules made by the Central Government in this behalf, for use by him in the manufacture or processing of goods for sale or in mining or in the generation or distribution of electricity or any other form of power". What is relevant is the goods as being intended for use by the dealer in the manufacture or processing of goods for sale. This is further amplified in R.13 of the Central Sales Tax (Registration and Turnover) Rules, 1957, which runs as follows: "13. The goods referred to in clause (b) of sub s.3 of S.8 which a registered dealer may purchase, shall be goods intended for use by him, as raw materials, processing materials, machinery, plant, equipment, tools, stores, spare parts, accessories, fuel, or lubricants, in the manufacture or processing of goods for sales or in mining, or in the generation or distribution of electricity or any other form or power". The anatomy of the provisions contained in Ss.7(1)(b), 8(3)(b) and R.13 would pinpoint that the goods as being intended for use by the dealer in the manufacture or processing of goods for sale as raw materials, processing materials, machinery, plant, equipment, tools, stores, spare parts, accessories, fuel or lubricants alone shall be specified in the certificate of registration. The anatomy of the provisions contained in Ss.7(1)(b), 8(3)(b) and R.13 would pinpoint that the goods as being intended for use by the dealer in the manufacture or processing of goods for sale as raw materials, processing materials, machinery, plant, equipment, tools, stores, spare parts, accessories, fuel or lubricants alone shall be specified in the certificate of registration. The fundamental requirement for specification of these goods in the certificate is that the dealer must be engaged in the manufacture or processing of goods for sale. In the absence of such activity dealer is not entitled to get the specification of the goods referred to in R.13 in the certificate of registration. This position is amply clear also from Form A application and Form B certificate of registration prescribed under the Rules. 5. The case of the assessee is that it is entitled to purchase bitumen compound, alkaline fibre and PVC cables by issuing C forms and purchases so made are in order. In this context, it may be recalled that all the three authorities uniformly found that the business of the assessee is only the sale of rubber produced in the estate. In other words, the assessee is carrying on the business of rubber plantation which consists of planting, maturing and maintaining the plants. Therefore, the question to be decided is whether the goods deleted from the Certificate of Registration are goods intended for use in the manufacture or processing of goods for sale. 6. The Supreme Court in Travancore Tea Estates Co. Ltd. v. State of Kerala (1977) 39 STC 1) had examined the ambit and scope of R.13 of the Central Sales tax (Registration and Turnover) Rules. That was a case where the assessee was carrying on the business of tea planting, owned tea estates and maintained separate tea factories in each of those estates for the manufacture of tea grown in those estates. One of the questions raised was whether fertilizers, chemicals, we a decides, insecticides etc. for use in tea cultivation could be said to be goods intended for use in the manufacture or processing of tea meant for sale within the meaning of S.8(3)(b) of the Act. The Supreme Court significantly noticed the vital difference between an agricultural operation and a manufacturing process. for use in tea cultivation could be said to be goods intended for use in the manufacture or processing of tea meant for sale within the meaning of S.8(3)(b) of the Act. The Supreme Court significantly noticed the vital difference between an agricultural operation and a manufacturing process. Ultimately, the apex court said: "Cultivation and growth of tea plants and leaves cannot be comprehended in the "in the manufacture or processing of goods for sale'. Although cultivation and growth of tea plants results in the production of raw materials in the form of green tea leaves which are ultimately processed into tea meant for sale, such cultivation and growth are in the very nature of things prior to the manufacturing process and do not answer to the description of manufacture and processing of tea meant for sale". The above observation squarely applies to the facts of the present case. 7. The conclusion therefore, is that the orders passed by the authorities below are valid and legal. No grounds for interference are made out. The writ petition is accordingly dismissed. No order as to costs.