Judgment :- Ramachandran Nair, J. The question raised is whether the Sales Tax Appellate Tribunal was justified in confirming levy of tax under Section 5A of the KGST Act on purchase of green tea leaves by the petitioner used in the production of manufactured tea for export. We have heard counsel for the petitioner and Government Pleader. 2. It is seen from the Tribunal’s order that petitioner being a SSI unit is enjoying sales tax exemption. It is also entitled to the benefit of Explanation to charging entry 150(i) of the First Schedule to the Act, which is as follows: Where a tax has been levied in respect of manufactured tea, the tax, if any, levied and collected in respect of green tea leaves from which such manufactured tea is produced shall be refunded. Since tax was payable on local sales in auction and inter-State sales of manufactured tea, petitioner was granted exemption from purchase tax under Section 5A. Purchase are admittedly from unregistered dealers, namely, small growers and dealers and so much so, tax is payable under Section 5A when green tea leaves are consumed in the production of manufactured tea. Since export turnover of manufactured tea does not attract sales tax, the Tribunal upheld the levy of tax under Section 5A on purchase of green tea leaves. 3. Counsel for the petitioner relied on the decision of this Court in Cottanad Plantation Ltd. V. State of Kerala, 85 STC 40, and contended that green tea leaves and manufactured tea are one and the same and so much so when purchased green tea leaves are exported, though after manufacture, the same qualifies for exemption under Section 5(3) of the CST Act. We are unable to accept this contention for the reason that item purchased is entirely different from item exported because green tea leaves as such is a perishable commodity and it is not the same as manufactured tea. Tea manufacture is a complicated process done in a factory and both the items are commercially different. This position is recognized in the charging entry which provides for refund of tax in respect sales tax paid whether at sale point or purchase point on green tea leaves, when tax is levied on the sale of manufactured tea produced out of the same. Section 5(3) provides for exemption on sale or purchase of goods made against prior order for export. Section 5(3) provides for exemption on sale or purchase of goods made against prior order for export. Petitioner has no case, and cannot have a case, that they have purchase order for export of green tea leaves, which is a perishable commodity with no consumer-use. So long as green tea leaves are not exported, and what is exported is manufactured tea, petitioner is liable to pay tax under Section 5A on the purchase turnover of green tea leaves consumed in the production of manufactured tea exported. The decision relied on by the petitioner does not lay down that green tea leaves and manufactured tea are one and the same. All what is stated is that green tea leaves also attract tax under the Act as the same falls within the meaning of “tea”. In fact, the liability for sales tax for green tea leaves and manufactured tea are synchronized in entry 150(i) to prevent spiraling tax effect on the ultimate produce, namely, manufactured tea. In view of the above findings, we dismiss the Tax Revision by affirming the order of the Tribunal.