S. R. NAYAK, J. ( 1 ) THESE TRCs. are directed against the common order dated 25. 4. 1992 passed by the Sales Tax Appellate tribunal, Andhra Pradesh, Hyderabad (for short, the Tribunal) in T. A. Nos. 1425 and 1426 of 1988. ( 2 ) A short question that arises for decision in these T. R. Cs. , is whether raw rubber sheets were classifiable under Entry 101 of the First Schedule to the A. P. General sales Tax Act, 1957 (for short, APGST Act) or it was taxable as a general item. ( 3 ) THE petitioner in both the T. R. Cs. , is M/s Scindia Rubber Works. The petitioner is a dealer in rubber and is an assessee on the rolls of the Commercial Tax Officer, VI circle, Hyderabad for the assessment year 1978-79 and was assessed to tax through proceedings dated 14. 1. 1980 in Assessment no. 3267/78-79. The petitioner had reported a total turnover of Rs. l4,56,363. 80ps and a net turnover of Rs. 14,56,363. 80ps. The assessment Officer did not accept the turnover reported by the petitioner and had assessed the petitioner to a net turnover of rs. l4,91,292. 30ps which was subjected to tax at 6% being the rate of tax as per entry 101 of the First Schedule to the apgst Act plus additional levies and the tax aggregating to a sum of Rs. 95,621. 91ps. The petitioner being aggrieved by the order of assessment made by the Commercial Tax officer subjecting the turnover of the petitioner s goods to tax at 6% treating the same as falling under Entry 101 of the First schedule to the APGST Act preferred an appeal to the Assistant Commissioner (Appeals) CT. Before the Assistant commissioner (Appeals) CT, the petitioner had contended that the goods sold by it being raw rubber and not an end product of rubber, the same should be taxed at the general rate i. e. , 4%. The Assistant commissioner (Appeals) CT by for his order dated 20. 3. 1980 set aside the order of the assessing Officer. The Deputy commissioner (CT) being of the opinion that the order of the Assistant Commissioner (Appeals) CT is improper, illegal and incorrect, had issued a show cause notice proposing to revise the orders of the assistant Commissioner (Appeals) through r. R. Proceedings No. 169/80 dated 25. 9. 1983. 3. 1980 set aside the order of the assessing Officer. The Deputy commissioner (CT) being of the opinion that the order of the Assistant Commissioner (Appeals) CT is improper, illegal and incorrect, had issued a show cause notice proposing to revise the orders of the assistant Commissioner (Appeals) through r. R. Proceedings No. 169/80 dated 25. 9. 1983. The view of the Deputy Commissioner (CT) was that there is no product known as raw rubber obtained from latex, but different names were given to products according to its contents and method of production and since there is no production or name was given to the commodity yielded from latex as raw rubber , the raw rubber sheets sold by the petitioner would fall under entry 101 of the First Schedule to the apgst Act and liable to tax at 6%. Before the Deputy Commissioner (CT), it was contended on behalf of the petitioner that the product sold by it is raw rubber and not a finished rubber product and, therefore, it does not fall under Entry 101 of the First schedule to APGST, Act. The Deputy commissioner (CT) did not accept the above contention of the petitioner and by his order dated 31. 3. 1984 revised the order of the assistant Commissioner (CT) Appeals and restored the assessment order dated 4. 1. 1980 of the Assessing Officer, holding that the turnover relating to sale of raw RMA sheets i. e. , a sum of Rs. l4,91,292. 30ps is liable to tax at 6% and directed the Commercial Tax officer to realize the differential tax of 2% on the turnover. ( 4 ) THE petitioner being aggrieved by the said order of the Deputy Commissioner (CT) preferred further appeals to the learned tribunal numbered as T. A. Nos. 1425 and 1426 of 1988. The Tribunal, agreeing with the view taken by the Deputy Commissioner (CT), dismissed the Appeals by its common order dated 25. 4. 1992, which impugned in these TRCs. The Tribunal while dismissing the appeals held that the RMA sheets sold by the petitioner would fall under the entry rubber product mentioned in Entry 101 of the First Schedule to the APGST Act and such entry includes various kinds of goods mentioned in sub-items (i) to (iv) and the goods sold by the petitioner viz. The Tribunal while dismissing the appeals held that the RMA sheets sold by the petitioner would fall under the entry rubber product mentioned in Entry 101 of the First Schedule to the APGST Act and such entry includes various kinds of goods mentioned in sub-items (i) to (iv) and the goods sold by the petitioner viz. , raw RMA sheets would fall under sub-item (ii) of entry 101 of the First Schedule to the apgst Act as the said entry deals with rubber sheets, striped Unhardened. ( 5 ) SRI S. Ravi, learned counsel for the petitioner would contend that raw RMA sheets are nothing but dried latex and natural rubber and it is not a finished product. Therefore, such goods could not be brought under Entry 101 of the First Schedule to apgst Act. The learned counsel would maintain that in order to be a rubber product mentioned in Entry 101 of the First Schedule to the APGST Act, such a product is expected to undergo some manufacturing process or such goods should emerge out of some activity which could be termed as production in ordinary parlance. The learned counsel would maintain that raw rma sheets are not the outcome of any manufacturing process or the outcome of any activity which could be termed as production as that term is understood in ordinary parlance. The learned counsel, in support of his contention, would draw our attention to certain provisions of the booklet rubber Growers Companion published by the Rubber Board, in 1974. This booklet deals with processing of the crop from rubber plantations for marketing. The learned Counsel would also rely on the decision of the Supreme Court in Karnataka Forest Development corporation Ltd. v. Cantreads Pvt. Ltd and others, (1994) 95 STC 561 and the decision of the Madras High Court in Okay Rubber corporatin v. State of Tamil Nadu, (1984) 55 STC 247 . ( 6 ) ON the other hand, learned Special g. P. for Taxes while supporting the view taken by the learned Tribunal would contend that RMA rubber sheets prepared out of latex or natural rubber cannot be considered as such latex or natural rubber, for such sheets are prepared by subjecting the raw rubber to some manufacturing process. ( 6 ) ON the other hand, learned Special g. P. for Taxes while supporting the view taken by the learned Tribunal would contend that RMA rubber sheets prepared out of latex or natural rubber cannot be considered as such latex or natural rubber, for such sheets are prepared by subjecting the raw rubber to some manufacturing process. The learned GP would maintain that latex or natural rubber and RMA rubber sheets are different goods and they cannot be treated as one and the same for interpreting the term rubber products occurring in entry 101 of the First Schedule to the apgst Act. In support of his submissions, the learned GP would place reliance on certain decisions of the Supreme Court and of this Court. ( 7 ) THE contention of the learned counsel for the petitioner that RMA rubber sheets sold by the petitioner-assessee are not different from latex or natural rubber, and as such RMA rubber sheets cannot be treated as rubber products mentioned in entry 101 of the First Schedule to the apgst Act, is not acceptable to us. It has come in the evidence that in order to prepare RMA rubber sheets out of latex or natural rubber, latex of natural rubber has to be subjected to certain processes. As could be seen from the contents of the booklet the crop from the rubber tree known as latex, a milky liquid, is harvested by the process of tapping and it is channeled into coconut shell cups and later it is collected in buckets. Latex is highly susceptible to degradation due to contamination and, therefore, it essential to process it into a form that will allow easy storage an marketing v without degradation. The booklet also deals with important forms in which the crop from rubber plantations can be marketed. They are (i) preserved latex and latex concentrates, (ii) dry ribbed sheet rubber, (iii) dry crepe rubbers and (iv) dry solid block rubbers. In the booklet it is also stated that the crop collected in the form of liquid latex can be processed into any of the above forms. But the crop collected in the form of tree lace, shell scrap and earth scrap can be processed only into crepe or solid block rubbers. In the booklet it is also stated that the crop collected in the form of liquid latex can be processed into any of the above forms. But the crop collected in the form of tree lace, shell scrap and earth scrap can be processed only into crepe or solid block rubbers. Dealing with the process, of preservation of latex or latex concentrates, it is stated as follows:-"latex is a white or slightly yellowish opaque liquid with a specific gravity which varies between 0. 974 and 0. 986. It is a week lyophillic colloidal system of spherical or pear shaped rubber globules suspended in an aqueous serum. . . Fresh latex as it comes out from the tree is slightly alkaline or neutral but since it is an excellent medium for the growth of bacteria like milk, it becomes acidic rapidly due to bacterial action and gets coagulated or clotted on keeping. Therefore, fresh latex cannot be kept for long without pre-coagulation. ""wet, bleached and virgin rubber and rubber that is not completely dry at the time of buyers inspection is not acceptable for any of the RMA official types (except slightly undercured rubber as specified under 5 ribbed smoked sheet description. Skin latex coagula shall not be used in whole or in part for producing any of the RMA types. Copper or manganese content in any RMA, type and grade of rubber shall not exceed the following maximum tolerances: copper 8 parts and Manganese 10 per million. ""nothing but ribbed smoked sheets of rubber can be used in making these grades; cuttings, block or frothy sheets or other scrap, air-dried sheets or smooth sheets not permissible. " ( 8 ) IN addition the booklet also deals with the methods of anti-coagulation and preservation, type descriptions and packing specifications for natural rubber adopted by the Rubber Manufacturers Association on, new York and endorsed by the Rubber trade Association of New York. Several processes mentioned in the booklet would clearly indicate that RMA rubber sheets are obtained by processing the natural latex rubber. In view of the several processes mentioned in the booklet and having regard to the fact that RMA rubber sheets which are sold after packing them in bales with hession wrappers in the market, the RMA rubber sheets cannot be treated as latex or natural rubber. In view of the several processes mentioned in the booklet and having regard to the fact that RMA rubber sheets which are sold after packing them in bales with hession wrappers in the market, the RMA rubber sheets cannot be treated as latex or natural rubber. In other words, RMA rubber sheets are different goods than latex or natural rubber. RMA sheets are end products of the processes already noticed above or rubber products mentioned in Entry 101 of the First Schedule to APGST Act. In taking this view, we are also supported by the judgments of the Supreme Court in vijayalakshmi Cashew Co. and others v. Deputy Commercial Tax Officer, (1996) 100 stc 571 , K. A. K. Anwar and Co. v. State of tamil Nadu, (1998) 108 STC 258, Rajasthan roller Flour Mills Association and Anr. , v. State of Rajasthan, (1991) 91 STC 408 and the decisions of this Court in State of A. P. v. M/s. India Rrubbers, (1989) 8 APSTJ 171, Al-Kabeer Exports Ltd. V. Commissioner of Commercial Taxes, (2000) 3 APSTJ 58. ( 9 ) IN Vijayalakshmi Cashew Co. case (supra), the Supreme Court held that raw cashew nuts and cashew kernels are different goods. In K. A. K. Anwar s case (supra), the Supreme Court held that dressed hides and skins are different from raw hides and skins. To the same effect is the Judgment of this Court in Al-Kabeer Exports Ltd case (supra ). In Rajasthan Roller Flour Mills association case (supra), the Supreme court held that flour, maida and suji derived from wheat are not wheat and not declared goods. In M/s India Rubber s case (supra), the question that arose for decision was whether tread rubber can be treated as an article made of rubber within the meaning of Entry 41 of the First schedule to the APGST Act. While considering the said question, this Court held that it would be more appropriate to place tread rubber under Entry 101 as rubber or atleast as a rubber product rather than placing it under Entry 41 as an article made of rubber. Further, the judgment of the Madras High Court, in okay Rubber Corporation case (supra), clearly supports the view taken by us. In that case also the question that arose for consideration was whether RMA rubber can be treated as raw rubber, viz. , latex as defined in item. Further, the judgment of the Madras High Court, in okay Rubber Corporation case (supra), clearly supports the view taken by us. In that case also the question that arose for consideration was whether RMA rubber can be treated as raw rubber, viz. , latex as defined in item. 74 of the First Schedule to the Tamil Nadu General Sales Tax Act, exigible to 5% sales tax. Dealing with this question, the Madras High Court has opined that RMA rubber sheets packed in bales and hession wrapper is a processed rubber goods and is commercially a different commodity from raw rubber i. e. , latex. ( 10 ) HOWEVER, Sri S. Ravi, learned counsel for the petitioner drawing; our attention to the following provisions of the booklet at pages 44, 47 and 49 page 44:"the crop from the rubber tree is latex, a milky liquid, which, as mentioned elsewhere, is harvested by the process of tapping. "page 47:"there is good market for preserved latex concentrate as it is an important raw material that finds its way into a wide spectrum of uses. . . . "page 49:"latex when coagulated in suitable containers into thin slabs of coagulum and sheeted through a set of rollers consisting of a grooved set and dried, givers marketable forms of ribbed sheet rubbers. Depending upon the drying method, sheet rubbers are classified into two, the ribbed smoked sheets and the air dried sheets (pale amber unsmoked sheets ). The major quantity of natural rubber produced in this country is marked in the sheet form at present as it is the oldest and simplest method of processing latex into a marketable form. "would contend that RMA rubber sheets are nothing but coagulated natural rubber and that is the ordinary form in which raw rubber is marketed. The above provisions of the booklet no way advance the case of the petitioner. The above noticed provisions would only establish that it is necessary to subject the latex or natural rubber to certain processes in order to convert the same into a good marketable product. In a sense, the above provisions of the booklet to which the learned counsel for the petitioner has drawn our attention would support the view taken by the learned Tribunal. Similarly, the judgment of the Supreme Court in Karnataka forest Development Corporation Ltd. case (supra) is of no help to the petitioner. In a sense, the above provisions of the booklet to which the learned counsel for the petitioner has drawn our attention would support the view taken by the learned Tribunal. Similarly, the judgment of the Supreme Court in Karnataka forest Development Corporation Ltd. case (supra) is of no help to the petitioner. In that case, the short question that arose for decision before the Apex Court was whether rubber sheets of various grades supplied by the State of Karnataka and the karnataka Forest Plantation Corporation to the private limited companies were forest produce within the meaning of Karnataka forest Act, 1963, and hence liable to payment of Forest Development Tax under section 98a thereof. In dealing with that question, the Apex Court has opined that rubber sheets of various trades produced by hardening latex by application of Sulphuric acid and given the shape and form of sheets and, thereafter dried with the help of smoke and graded into grades and supplied by the State or the State Forest Plantation corporation to private limited companies are forest produce within the meaning of karnataka Forest Act, 1963 and hence liable to payment of Forest Development Tax under Section 98a of the said Act. But it is very pertinent to notice that the Apex court itself in that Judgment made it clear that the understanding or knowledge of an item subject to sales tax by the common man or persons dealing in it in the market is different from technical mind botanical sense of the same item and that the test of commercial parlance used in Sales Tax matters cannot be applied while considering the definition of forest produce . The supreme Court observed"the test of commercial parlance while considering entries in Sales Tax was evolved is the tax under the sales tax enactments is normally either on sale or purchase or on manufacture or import, etc. , Therefore, it is the understanding or the knowledge of the item by the common man or persons dealing it in the market and not in the technical or botanical sense which was accepted by this Court as the deciding factor. But that test cannot be applied while considering the definition of "forest produce". ( 11 ) IT is trite that the Tribunal is the final fact finding authority under the apgst Act. The finding recorded by the tribunal is a finding on question of fact. But that test cannot be applied while considering the definition of "forest produce". ( 11 ) IT is trite that the Tribunal is the final fact finding authority under the apgst Act. The finding recorded by the tribunal is a finding on question of fact. The finding recorded by the Tribunal cannot be said to be perverse or based on no evidence . ( 12 ) IN the result and for the foregoing reasons, we do not find any error or flaw in the order of the Tribunal and it does not call for our interference. The T. R. Cs. , are accordingly dismissed with no order as to costs.