H. L. DATTU, J. ( 1 ) THE appellant is a dealer in Chemical Fertilizers and Chemical Fertilizer Mixtures. It is registered both under the provisions of Karnataka Sales Tax Act, 1957 (KST 'act' for short) as well as the Central Sales Tax Act, 1956 (CST 'act' for short ). For the assessment years 1993-94, 1994-95, 1995-96, 1996-97 and 1997-98 the assessing authority had concluded re-assessment proceedings under Section 12-A of the Act vide his order dated 24. 2. 2000 and had levied turnover tax under Section 6-B of the Act on the sales turnover of Chemical Fertilizer Mixtures obtained out of KST-suffered Chemical Fertilizers being of the view that what is exempted under the notification dated 29. 6. 1981 and subsequent notifications is only Chemical Fertilizers from the levy of turnover tax and not Chemical fertilizer Mixtures. ( 2 ) THESE re-assessment proceedings were subject matters of appeals before the first appellate authority. By a common order dated 29. 6. 2000, the first appellate authority has allowed all the appeals and has set aside the levy of turnover tax on Chemical Fertilizer Mixtures. ( 3 ) THE revisional authority being of the view that the order passed by the first appellate authority is not only erroneous but also prejudicial to the interest of the revenue, had initiated proceedings by issuing a notice under Section 22-A (1) of the Act, interalia directing the assessee to show cause why the orders passed by the first appellate authority dated 29. 6. 2000 should not be set aside and the orders passed by the assessing authority should not be restored. ( 4 ) THE assessee-dealer had filed its detailed statement of objections, interalia contending that there is no essential difference between the Chemical Fertilizers and Chemical Fertilizers mixtures and therefore, the first appellate authority was justified in setting aside the order passed by the assessing authority in levying the turnover tax on the sales turn over of Chemical fertilizers Mixtures obtained out of KST-suffered Chemical Fertilizer. ( 5 ) THE revising authority keeping in view the purpose and the object of the notification and also the language employed therein, has come to the conclusion that the State Government has exempted only Chemical Fertilizers from the levy of turnover tax effected by second or subsequent dealer and not Chemical Fertilizer Mixtures and therefore, the first appellate authority was not justified in allowing the appeals and thereby deleting the levy of turnover tax on the sales turnover of Chemical Fertilizer Mixtures obtained out of KST-suffered Chemical fertilizer. Aggrieved by the said order passed by the revisional authority in SMR No. 52/02-03 dated 18. 10. 2002, the appellant is before this Court. ( 6 ) SRI Keshava Murthy, learned Counsel appearing for the appellant would strenuously contend before this court that Chemical Fertilizer and Chemical Fertilizer Mixtures are one and the same. Therefore, the first appellate authority was justified in setting aside the orders passed by the assessing authority in levying turnover tax on the sales turnover of Chemical Fertilizer Mixtures obtained out of KST-suffered Chemical Fertilizers. In support of that contention the learned counsel has taken us through Entry 11 of the Second Schedule to the KST Act and also the explanation appended to the Second Schedule to the Act. The learned Counsel also relies upon the observations made by a Division Bench of the Andhra Pradesh High Court in the case of state OF A. P v. MINERALS AND METALS TRADING CORPORATION OF INDIA LTD. , (2000) 118 STC 90 2 and the observations made by the Apex Court in the case BOMBAY chemical PVT. LIMITED v. COLLECTOR OF CENTRAL EXCISE, [1995] 99 STC 339 bombay. ( 7 ) PER contra, Sri Anand, learned Government Advocate justifies the impugned order passed by the revisional authority. ( 8 ) IN order to resolve the controversy in these appeals, in our opinion Entry 11 of part 'c' of the second Schedule to the Act requires to be extracted. It reads as under; "11 (i) Chemical fertilizers other than those falling under item (ii) below, (ii) Chemical fertilizer mixtures of two or more chemical fertilizers on the turnover relating to components thereof viz, individual chemical fertilizers which have not already suffered tax". ( 9 ) THE notification issued by the State Government in FD. 32. CSL. 81 (1) dated 28. 6. ( 9 ) THE notification issued by the State Government in FD. 32. CSL. 81 (1) dated 28. 6. 1981 which is being continued from time to time up-to 1998 has granted exemption from the levy of turnover tax in respect of chemical fertilizers on the second and subsequent sales. ( 10 ) ANALYSIS of Entry 11 of the Second Schedule; the Second Schedule to the Act enumerates goods on the sale of which a single point tax is leviable on the first or earliest of successive dealers in the State under Section 5 (3) (a) of the Act. Entry 11 (i) speaks of Chemical Fertilizers other than those falling under item (ii ). Entry 11 (ii) of the Second Schedule to the Act speaks of chemical fertilizer mixtures of two or more chemical fertilizers on the turnover relating to components thereof, viz, individual chemical fertilizers which have not already suffered tax. The expression "chemical Fertilizers" occurring in the opening part of the Entry speaks of individual chemical fertilizers and the Legislature specifically excludes items falling under sub-entry (ii) from chemical fertilizers. The chemical fertilizer mixture is a mixture of two or more chemical fertilizers. The mixtures and its components have different chemical properties of their own and their use is also different. If an assessee purchases chemical fertilizers and brings about a new product by mixing one or more of the said products, the mixed product cannot be said to be chemical fertilizers and the mixed product will have different properties of its own and it cannot be said that it retains the same characteristics or properties of any one of the chemical fertilizers which went to make up the resultant mixture. Secondly, the intention of the Legislature appears to be clear and unambiguous. The intention is to levy single point tax on chemical fertilizers and chemical fertilizer mixtures. Therefore, the legislature under Entry 11 (ii) of the Schedule to the Act intends to levy tax on chemical fertilizer mixtures on such of the components, which have not already suffered tax. Thirdly, even in common parlance and also in commercial parlance, the expressions "chemical fertilizers" and "chemical fertilizer mixtures" are understood as different commercial commodities. ( 11 ) WHAT is a chemical fertilizer mixture did come up for consideration before the Division bench of this Court in SHAW WALLACE CO. LTD. Thirdly, even in common parlance and also in commercial parlance, the expressions "chemical fertilizers" and "chemical fertilizer mixtures" are understood as different commercial commodities. ( 11 ) WHAT is a chemical fertilizer mixture did come up for consideration before the Division bench of this Court in SHAW WALLACE CO. LTD. , v. STATE OF KARNATAKA, (1992) 36 klj 478 in the said decision the Court had an occasion to notice how a Chemical Fertilizer mixture is prepared in the market. The Court has observed that; "in the preparation of Fertilizer Mixtures the petitioner has to necessarily had a few other articles such as leather meal, neem cake meal gypsum etc. However, the ultimate product that is obtained out of mixing all these with leather meal neem cake meal, gypsum etc, would be a Chemical fertilizer Mixture". ( 12 ) IN Re. SHAW WALLACE AND CO. LTD v. THE STATE OF TAMILNADU, AIR1976 SC 1437 , (1976 )3 SCC17 , [1976 ]3 SCR795 , [1976 ]37 stc522 (SC ), 1976 (8 )UJ397 (SC ) the assessee was a manufacturer and dealer in chemical fertilizers. It also prepared fertilizer mixtures by mixing various chemical fertilizers and fillers like china clay, gypsum etc, by a shovel. The question before the Court was whether the sales of such fertilizer mixtures could be considered as second sales since components had already suffered tax. The Apex Court held that the fertilizer mixture is not the same article as the ingredients composing it. It is sold as a different commercial product. It is put to different use and has different chemical properties and therefore it has to be treated as a different article from its components. Further, the Court has observed that the question whether there is manufacturing process or not is irrelevant. ( 13 ) FERTILIZER is a substance that is added to soil to help plants to grow. Fertilizers contain nutrients that are essential for plant growth. Some fertilizers are made from organic waste, such as manure or sewage. Others are manufactured from certain minerals or synthetic compounds produced in factories. There are two kinds of fertilizers, namely, mineral and organic. Manufacturers produce mineral fertilizers from certain minerals or synthetic substances. Organic fertilizers come from decayed plant or animal matter. Fertilizer is produced in four basic forms. Straight good fertilizer is any chemical compound that contains one or two fertilizer elements. There are two kinds of fertilizers, namely, mineral and organic. Manufacturers produce mineral fertilizers from certain minerals or synthetic substances. Organic fertilizers come from decayed plant or animal matter. Fertilizer is produced in four basic forms. Straight good fertilizer is any chemical compound that contains one or two fertilizer elements. Bulk blend fertilizer is a mixture of straight goods in certain proportions. Manufactured fertilizer consists of two or more chemicals that are mixed and then formed into small grains. Chemical fertilizer mixtures consist of two or more chemical fertilizers in addition to a few other articles such as gypsum, leather meal, etc. The chemical fertilizer mixtures that are produced out of two or more chemical fertilizers are different commercial commodities since it has different use and has different chemical properties. ( 14 ) NOW let us notice the notification issued by the state Government in No. FD. 32 CSL 81 (1) dated 29. 6. 1981. The notification reads as under; "in exercise of the powers conferred by Section 8-A of the Karnataka Sales Tax Act, 1957 (Karnataka Act 25 of 1957), the Government of Karnataka hereby exempts, with effect from 1st july 1981, the turnover tax payable under Section 6-B of the said Act by registered dealers, on the second and subsequent sales of the following goods in the State namely: (i) Chemical Fertilizers bone-meal and oil cake, and (ii) Insecticides and pesticides". ( 15 ) THE analysis of the aforesaid notification is as under; the notification is issued by the State Government in exercise of its powers conferred under section 8-A of the Act. The exemption is with effect from 1. 7. 1981 and being continued from time to time what is exempted under the notification is the turnover tax payable under Section 6-B of the Act by a registered dealer on his second and subsequent sales of chemical fertilizers. ( 16 ) THE expressions in an exemption notification should be understood by the language employed therein. The benefit of the notification can be extended to a dealer, if he falls squarely within the four corners of the notification. ( 16 ) THE expressions in an exemption notification should be understood by the language employed therein. The benefit of the notification can be extended to a dealer, if he falls squarely within the four corners of the notification. ( 17 ) KEEPING in view the object of the notification, the language employed in the notification and the specific entries in Entry 11 of the Second Schedule to the Act, in our opinion, the State government while issuing notification has exempted only chemical fertilizers simpliciter, and not a mixture of two or more chemical fertilizers. If it is understood in that manner, in our opinion, the revisional authority was justified in invoking his powers under Section 22-A of the act to set at naught the orders passed by the first appellate authority, who had mis-understood the language employed in the notification to grant exemption on the sales turnover of chemical fertilizer mixtures under Section 6-B of the Act. Since the order passed by the revisional authority is in consonance with Entry 11 of the Second Schedule to the Act and the language of the notification, we are of the view that the revisional authority was justified in annulling the order passed by the first appellate authority and in restoring the order passed by the assessing authority. ( 18 ) IN view of the above, appeals fail and they are rejected. Ordered accordingly.