JUDGMENT K. K. USHA, J. - Assessee is the revision petitioner. Challenge is against the order passed by the Kerala Sales Tax Appellate Tribunal, Additional Bench, Ernakulam in T.A. No. 474 of 1987. Following are the questions raised for decision of this Court : "1. Whether, on the facts and in the circumstances of the case the finding of the Tribunal that rubber sheets used in the manufacture of rubber chappals come under sub-section (3A) of section 5 and not sub-section (3) correct ? 2. Is not sub-section (3) intended to apply to component parts which are visually identifiable within the meaning of the Explanation thereunder ? Is not rubber sheets are visually identifiable component within the meaning of the Explanation ? 3. Whether, on the facts and circumstances, the finding of the Tribunal that Notification S.R.O. No. 643/81 has become inoperative and stood repealed by implication by the introduction of sub-section (3A) of section 5 correct in the light of established principles of interpretation ? Is it not cardinal principle governing interpretation of statutory provisions ? When there is ambiguity or conflict, should not an interpretation favorable to the taxpayer be taken ? 4. Is not sub-section (3A), a general provisions applicable to industries in general and the notification S.R.O. No. 643/81 a special provision applicable to rubber industries particular; should not a special provision prevail over general provision in the matter applicability ?" 2. The petitioner-assessee is engaged in manufacture of rubber sheets used for making chappals. The relevant assessment year is 1984-85. During the period rubber sheets were liable to be taxed at 12 per cent under entry 40 of the First Schedule to the Kerala General Sales Tax Act. In exercise of its power under section 10 of the Kerala General Sales Tax Act, 1963 (hereinafter referred to "the Act"), Government issued S.R.O. No. 643/81 providing a reduction in the rate of tax payable under the said Act on the purchase of rubber sheets used for manufacture of chappals to 4 per cent subject to the condition that the manufactured products are sold within the State, or inter-States; and the selling dealer who claims the concessional rate furnishes to the assessing authority a declaration obtained from the purchasing dealer in the form appended to the notification. It is also provided that the notification shall be deemed to have come into force on the 1st day of April, 1981. 3. From April 1, 1981 onwards the assessee collected tax only at the rate of 4 per cent from dealers who furnished certificate as provided in the above notification. The assessing authority allowed the claim and reduced the rate of tax for the assessment years up to 1983-84, but for the year 1984-85 such benefit was denied. The assessing authority took the view that on the introduction of sub-section (3A) of section 5 with effect from October 14, 1982 it should be taken that thereafter S.R.O. No. 643/81 would not govern the field and assessee is liable to produce declaration in form No. 18 as provided under sub-section (3A) of section 5. Since the declaration produced by the assessee was in the form prescribed under S.R.O. No. 643/81, the assessee is liable to assess tax at 12 per cent. The above finding of the assessing authority was affirmed by the first appellate authority. The Tribunal also took the view that even though S.R.O. No. 643/81 has not been specifically cancelled by the Government, the same has been made inoperative by virtue of enactment of sub-section (3A) of section 5 with effect from October 14, 1982. The above findings are under challenge in this petition. 4. When originally S.R.O. No. 643/81 was issued on June 2, 1981 with effect from April 1, 1981 there was no general provision under section 5 of the Act which provided a lower rate of tax in respect of any sale of industrial raw material. The above findings are under challenge in this petition. 4. When originally S.R.O. No. 643/81 was issued on June 2, 1981 with effect from April 1, 1981 there was no general provision under section 5 of the Act which provided a lower rate of tax in respect of any sale of industrial raw material. Sub-section (3) of section 5 as it stood during the relevant period read as follows : "(3) Notwithstanding anything contained in sub-section (1) or sub-section (2), the tax payable by a dealer in respect of any sale of the goods mentioned in the First Schedule by such dealer to another for use by the latter as component part of any other goods mentioned in the said Schedule, which he intends to manufacture inside the State for sale, shall be at the rate of only one per cent on the taxable turnover relating to such sale : Provided that the provisions of this sub-section shall not apply to any sale unless the dealer selling the goods furnishes to the assessing authority in the prescribed manner a declaration duty filled in and signed by the dealer to whom the goods are sold containing the prescribed particulars in a prescribed form : Provided further that the goods sold are capable of being used as component part of any of the goods mentioned in the First Schedule." 5. By Amendment Act 3 of 1983, sub-section (3A) and sub-section (7) were introduced with effect from October 14, 1982. Sub-section (3A) dealt with sale of goods for use as component part as defined in Explanation to sub-section (3) of any other goods mentioned in the First Schedule. But sub-section (7) dealt with sale of industrial raw materials. By Amendment Act 3 of 1983, sub-section (3A) and sub-section (7) were introduced with effect from October 14, 1982. Sub-section (3A) dealt with sale of goods for use as component part as defined in Explanation to sub-section (3) of any other goods mentioned in the First Schedule. But sub-section (7) dealt with sale of industrial raw materials. Sub-section (7) reads as follows : "(7) Notwithstanding anything contained in sub-section (1) or sub-section (2), the tax payable by a dealer in respect of any sale of industrial raw materials or packing materials, which is liable to tax at a rate higher than four per cent, when sold to industrial units for use in the production of finished products inside the State for sale, or for packing of such finished products inside the State for sale, as the case may be, shall be at the rate of only four per cent on the taxable turnover relating to such industrial raw materials or packing materials, as the case may be : Provided that this sub-section shall not apply where the sale of such finished products is not liable to tax either under this Act or under the Central Sales Tax Act, 1956 (Central Act 74 of 1956) or when such finished products are exported out of the territory of India : Provided further that the provisions of this sub-section shall not apply to any sale unless the dealer selling the goods furnishes to the assessing authority in the prescribed manner a declaration duly filed in and signed by the dealer to whom the goods are sold, containing the prescribed particulars in the prescribed form." The above would clearly show that the finding of the authorities below that by introducing sub-section (3A) provisions similar to those contained in S.R.O. No. 643/81 were incorporated in the statute itself is not correct. Such provisions are made in sub-section (7) of section 5. Sub-section (3A) and sub-section (7) were deleted from the statute by Kerala Finance Act, 1987 (18 of 1987) with effect from July 1, 1987. Since we are dealing with the assessment year 1984-85, we have to consider a position with sub-section (7) in the statute book. 6. S.R.O. No. 643/81 was later superseded by S.R.O. No. 372/92 dated March 31, 1992 as per G.O. (P) No. 75/92/TD with effect from April 1, 1992. 7. Since we are dealing with the assessment year 1984-85, we have to consider a position with sub-section (7) in the statute book. 6. S.R.O. No. 643/81 was later superseded by S.R.O. No. 372/92 dated March 31, 1992 as per G.O. (P) No. 75/92/TD with effect from April 1, 1992. 7. It is true that when sub-section (7) was introduced in section 5 of the Act it contained provision for reducing rate of tax applicable generally to sale of industrial raw materials or packing materials which are liable to tax at a rate higher than 4 per cent, when sold to industrial units for use in the production of finished products inside the State for sale, etc. But the provisions contained under S.R.O. No. 643/81 related to such benefit of reduced rate of tax in respect of certain specified items like purchase of paper used for the manufacture of note books, plastics used for the manufacture of plastic goods and rubber sheets used for the manufacture of chappals. We are not persuaded to hold that by introduction of sub-section (7) in section 5 the provisions contained under S.R.O. No. 643/81 would become inoperative. As mentioned earlier, the provisions in sub-section (7) deal with generally sale of industrial raw materials or packing materials, etc., but S.R.O. No. 643/81 deals with three specific items. Since special provisions are made under S.R.O. No. 643/81 in respect of rubber sheets used for manufacture of chappals, we are of the view that it should prevail over general provisions contained under sub-section (7) of section 5 of the Act. 8. Apart from the above, we find that the Government also intended to continue the provisions contained under S.R.O. No. 643/81 even after the introduction of sub-section (7). It is clear from the provisions contained under S.R.O. No. 372/92 issued under G.O. dated March 31, 1992. 8. Apart from the above, we find that the Government also intended to continue the provisions contained under S.R.O. No. 643/81 even after the introduction of sub-section (7). It is clear from the provisions contained under S.R.O. No. 372/92 issued under G.O. dated March 31, 1992. The above order issued in exercise of the powers under section 10 of the Act specifically supersedes S.R.O. No. 643/81 among other orders and provides that the Government of Kerala having considered it necessary in public interest so to do makes a reduction in the rate of tax payable under the Act by the persons or units specified in the Schedule given under the order with regard to their turnover on the sale or purchase as the case may be of goods mentioned against them to the rates noted against each subject to such conditions specified therein. This would clearly show that the Government intended the provisions in S.R.O. No. 643/81 to continue in force till S.R.O. No. 372/92 was issued on March 31, 1992 with effect from April 1, 1992. 9. Apart from the above, we are of the view that even if there had been violation, it was only technical in nature. The contents of the declaration as contemplated in form 18 provided under sub-section (7) and the declaration provided under S.R.O. No. 643/81 are more or less of same nature. For this reason also we are of the view that the authorities below have wrongly declined the claim put forward by the assessee for being assessed at the rate of 4 per cent in respect of the rubber sheets purchased from it for the manufacture of chappals. We therefore set aside the orders of two appellate authorities and direct the assessing authority to modify the assessment order in the light of the findings in this judgment. The revision stands allowed as above. Petition allowed.