Judgment :- Radhakrishnan, J. Assessee has come up in this revision aggrieved by the order passed by the Sales Tax Appellate Tribunal, Addition Bench, Kozhikode. Following are the questions of law arising for our consideration. A. Whether the lower authorities are justified in declining the benefit of concessional rate in tax to the petitioner / assessee in respect of its sales of liquid sodium silicate made out of soluble glass, as claimed by them on the basis of SRO No.1091 of 1999, solely on the reasoning that part of the processing activity was carried out outside the State? B. Whether such claim for concession can be denied to an assessee solely on the ground that semi processed raw materials were procured from outside the Stat? Whether such an interpretation is possible or warranted on true construction of SRO No 1091 of 1999? Assessee is a small scale industrial unit engaged in the manufacture and sales of sodium silicate. For the assessment year 2000-2001 assessee returned a total and taxable turnover of Rs.64,70,547/- and Rs.60,77,670/- respectively. On verification of the books of accounts it was noticed by the assessing authority. That the assessee had effected direct inter-state purchase of soluble glass for Rs.4,44,975/- during the assessment year. Assessee raised a claim that it is eligible for concessional rate of tax as per SRO Nos.1729/93 and 1091/99 on the ground that conversion of sodium silicate into liquid silicate is not a manufacturing process as per SRO No.1729/93. According to the assessee, conversion of crystal sodium silicate into liquid sodium silicate involves a manufacturing process and hence assessee is entitled to get the benefit of SRO No.1091/99. Assessing authority took the view that conversion of sodium silicate into liquid sodium silicate is not a manufacturing process. Hence assessee is not eligible for concessional rate of tax at 8% on the sale of liquid sodium silicate as per SRO No.1091/99. Assessing authority therefore proposed to levy tax on the said turnover at the rate of 12%. Aggrieved by the said order assessee took up the matter in appeal before the Deputy Commissioner (Appeals). Appeal was dismissed holding that the assessee had not produced any proof that the entire process of manufacture has taken place within the State of Kerala and in the absence of any proof of purchase of raw materials used for manufacture of sodium silicate concessional rate cannot be allowed. Appeal was dismissed holding that the assessee had not produced any proof that the entire process of manufacture has taken place within the State of Kerala and in the absence of any proof of purchase of raw materials used for manufacture of sodium silicate concessional rate cannot be allowed. Matter was taken up in appeal by the assessee to the Tribunal. Tribunal dismissed the appeal against which this revision petition has been preferred. 2. Assessee has claimed the benefit of concessional rate of tax in view of SRO No 1091/99. The said SRO defines the expression “manufacture” as follows: “Manufacture” shall mean the use of raw materials and production of goods, commercially different from the raw materials used. The term “manufacture” shall not include mere packing, polishing, varieties of the same goods, sawing, garbling, processing one form of goods into another form of the same goods by mixing with chemicals of gas, fumigation or any other process, conversion of rubber latex into centrifuged latex, raw-rubber sheets, ammoniated latex, crepe rubber, crumb rubber or any other item falling or treating the raw-rubber in any form with chemicals to form a compound of rubber by whatever name the same is called”. (emphasis supplied) Records maintained by the assessee would indicate that manufacture of soluable glass was not effected within the State but was effected outside State on job work basis. Soda ash silica was supplied by the dealer for the said manufacture. Manufactured soluable glass was thereafter brought to the place of business of the assessee from where it was converted into liquid sodium silicate and sold locally. As per Schedule II, item 6 of SRO 1091/99 SSI units are eligible for reduced rate of tax at the rate of 8% only on the turnover of sale of goods manufactured by them within the State. Facts would indicate that what the assessee is doing in this case is just converting the manufactured sodium silicate to liquid sodium silicate which would not amount to manufacture and no manufacturing process is involved. The goods, both before and after conversion, are the same goods namely sodium silicate, but in two different forms. 3. The definition of the expression “manufacture” given in S.R.O. 1729/93 came up for consideration in Swapna Bone Meal Co.(P) Ltd v. District Level committed for S.T. Exemption (2004) 12 K.T.R. 183). The goods, both before and after conversion, are the same goods namely sodium silicate, but in two different forms. 3. The definition of the expression “manufacture” given in S.R.O. 1729/93 came up for consideration in Swapna Bone Meal Co.(P) Ltd v. District Level committed for S.T. Exemption (2004) 12 K.T.R. 183). The court held that the process of crushing bones and making it into bone pieces of the size and dimension required for a customer is only a conversion of bone from one form to another form and that is specifically excluded from the scope of manufacture under the definition clause provided in the notification, SRO 1729/93. While deciding the question as to whether element of manufacture is involved, we have to look at the raw materials used and the products manufactured. Definition clause excludes mere packing of goods, polishing, cleaning, grading, drying, blending or mixing different varieties or the same goods by mixing with chemicals or gas, fumigation or any other process applied for preserving the goods in good condition or for easy transportation, conversion of rubber latex into centrifugal latex, raw rubber sheet, ammoniated latex, crepe rubber, crumb rubber or any other item falling under entry 110 of the first schedule or treating the raw rubber in any form with chemicals to form a compound of rubber by whatever name called. In this case, manufacturing process was done outside the State of Kerala and the dealer was only converting the manufactured sodium silicate. The conversion of soluable glass into liquid sodium silicate is not a manufacturing process, since no manufacturing process was done in the unit. The assessee is therefore not eligible for the reduced rate of tax at 8% on the sales of sodium silicate. The assessing authority has therefore rightly assessed the turnover to tax at 12%. Revision therefore lacks merits and the same is dismissed.