JUDGMENT : R.K. Patra, J. - In this writ petition, the correctness/propriety of the order dated September 29, 1993 passed in Second Appeal No. 103(C) of 1991-92 is under challenge. By the impugned order the Full Bench of the Orissa Sales Tax Tribunal has held that exemption from Central sales tax is subject to the conditions and restrictions specifically stated in the relevant Government notification. 2. Facts : The petitioner is a private limited company registered under the Companies Act, 1956. It is engaged in the business of manufacturing and selling of T.V. receiver sets. It is a registered dealer under the Orissa Sales Tax Act, 1947 and the Central Sales Tax Act, 1956 (in brief "the CST Act"). It had originally disclosed a gross turnover of Rs. 16,700 in the annual return furnished on May 14, 1987 for the year 1986-87. In the course of assessment proceedings it submitted a revised return indicating gross sale turnover at Rs. 11,77,677.50. Before the assessing officer it claimed that the entire sales disclosed in the revised return are exempted sales on the ground that they were tax free sales inasmuch as it had not charged and collected any sales tax on the sales made in course of inter-State trade. The assessing officer found that the State Government in the Finance Department had not extended the benefit of tax exemption to the petitioner on sales on T.V. receiver sets. He accordingly held the entire turnover is taxable and taxed the same at 10 per cent giving rise to a demand of Rs. 1,17,768 under Rule 12(5) of Central Sales Tax (Orissa) Rules, 1957 by order dated October 7, 1987. The petitioner against the aforesaid order of assessment filed Sales Tax Appeal No. AA(*) 40/1987-88 before the Assistant Commissioner of Sales Tax, Appellate Unit, Bhubaneswar, who by order dated October 26, 1991 did not accede to the claim of exemption. He accordingly confirmed the assessment made by the assessing officer and dismissed the appeal. Being aggrieved by the order of the Assistant Commissioner, the petitioner filed Second Appeal No. 103(0/1991-92 before the Tribunal which came to be dismissed as per the impugned order dated September 29, 1993. 3. Shri Y. Das, learned Senior Counsel, contended that the Tribunal erred in not granting exemption to the petitioner from Central sales tax despite the fact that the exemption notification is unconditional and general in nature. 3. Shri Y. Das, learned Senior Counsel, contended that the Tribunal erred in not granting exemption to the petitioner from Central sales tax despite the fact that the exemption notification is unconditional and general in nature. In this connection, he referred to a Bench decision of this Court in Magnetix (India) Ltd. v. Assistant Commissioner of Sales Tax 75 (1993) CLT 405. Counsel for the department on the other hand submitted that exemption from Central sales tax u/s 8(2-A) of the CST Act on the sale or purchase of goods is available only when sale or purchase of such goods is generally exempt under the State sales tax law and the relevant Government notification being not a general exemption but a conditional one, claim for exemption is not tenable. 4. May it be noted that the Supreme Court in Pine Chemicals Ltd. v. Assessing Authority [1992] 85 STC 432 held that the dealers-assessees were entitled to claim the benefit of the provision contained in Section 8(2-A) of the CST Act in view of the exemption granted to them under the Jammu and Kashmir Government order No. 159. The Commissioner of Sales Tax, Jammu and Kashmir sought review of the aforesaid judgment and the Supreme Court by judgment dated October 24, 1994 in Commissioner of Sales Tax, Jammu and Kashmir v. Pine Chemicals Ltd. [1995] 96 STC 355 reversed its earlier opinion and has ruled that Section 8(2-A) of the CST Act requires specifically that exemption from Central sales tax must be a general exemption and not an exemption operative in specified circumstances or under specified condition. General exemption means that the goods are totally exempt from tax, and where the exemption from tax is subject to conditions or certain circumstances, there is no exemption from the tax generally. 5. To delineate the facts of the present case at hand, it is relevant to refer to entry No. 30-M of the Schedule of the list of exempted goods (it now stands omitted). For the sake of convenience, we may extract the entire notification by which entry No. 30-M came to be inserted. 5. To delineate the facts of the present case at hand, it is relevant to refer to entry No. 30-M of the Schedule of the list of exempted goods (it now stands omitted). For the sake of convenience, we may extract the entire notification by which entry No. 30-M came to be inserted. "EXTRAORDINARY Published by authority No. 209 Cuttack, Monday February 1, 1988/Magha 12, 1909 Finance Department Notification The 29th January, 1988 S.R.O. No. 81/88.--In exercise of the powers conferred by Section 6 of the Orissa Sales Tax Act, 1947 (Orissa Act 14 of1947), the State Government do hereby direct that the following amendments shall be made in the notification of the Government of Orissa in the Finance Department No. 20206-CTA-14/76-F dated the 23rd April, 1976 as amended from time to time and further direct that the said amendment shall be deemed to have come into force from the 1st April, 1986. AMENDMENT.--In the Schedule to the said notification for the entries in the columns (2) and (3) against serial No. 30-M occurring under column (1) the following entries shall be substituted and thereafter the following form 1-C shall be inserted, namely:-- Sl. No. Description of goods Condition and exception subject to which exemption has been allowed. (1) (2) (3) Sale by registered dealers of electronic goods manufactured in the State of Orissa by the existing and new electronic industries as declared by the State Electronics Development Corporation excluding the public sector undertakings/industries fully owned by the Government of Orissa or Government of India. The exemption shall be allowedfor the period from April 1, 1986 or from the date of start of commercial production thereafter up to March 31, 1991 subject to production of a certificate in form 1-C appended below from the Orissa State Electronics Development Corporation, Bhubaneswar." (emphasis * supplied) On a bare perusal of the aforesaid notification it would appear that sales by registered dealers of electronic goods manufactured in the State of Orissa by the existing and new electronic industries, as declared by the State Electronics Development Corporation, shall be exempt from tax subject to the conditions and exceptions mentioned therein. It means that sale of such goods under the sales tax law of the State was not exempted from levy of tax generally, but subject to fulfilment of conditions and restrictions mentioned therein. 6. It means that sale of such goods under the sales tax law of the State was not exempted from levy of tax generally, but subject to fulfilment of conditions and restrictions mentioned therein. 6. As held by the Supreme Court in the second Pine Chemicals' case [1995] 96 STC 355[1995] 96 STC 355 the idea behind Section 8(2-A) of the CST Act is to exempt the sale/purchase of goods from the Central sales tax where the sale or purchase of such goods is exempted generally under the State sales tax law. Due regard and due meaning to the word "generally" must be given when it has been defined in the explanation to the aforesaid provision. Subsection (2-A) requires specifically that such exemption must be a general exemption and not an exemption operative in specified circumstances or under specified conditions. 7. As noted above, the exemption of tax on sale of electronic goods manufactured by the petitioner inside the State of Orissa was not generally exempt under the State law and the same was hedged by specified condition and restriction. Accordingly, sales made by it in course of inter-State trade would not be exempt from payment of Central sales tax. For the reasons aforesaid, the impugned order of the Tribunal cannot be faulted with. 8. Before parting with the case, we may state that the judgment of this Court in Magnetix (India) Ltd. 75(1993) CLT 405 was based on the ratio of the Supreme Court in the first Pine Chemicals case, i.e. [1992] 85 STC 432 (Pine Chemicals Ltd. v. Assessing Authority) which judgment has now been reversed in [1995] 96 STC 355 (Commissioner of Sales Tax, Jammu and Kashmir v. Pine Chemicals Ltd.) In view of this, the judgment of this Court in Magnetix (India) Ltd.75 [1993] CLT 405 no more holds the field. In the result, we do not find any merit in this writ petition which is accordingly dismissed. CH. P.K. MISRA, J.--I agree. Final Result : Dismissed