JUDGMENT : 1. Since both the ST Revisions involve same question of law and have been filed by the same Petitioner, they were heard together and are disposed of by this common judgment. 2. The question of law raised by the Petitioner is as follows: Whether broom sticks bunched together for broom serves the same purpose and shall be same purpose and shall be same commodity ? 3. The facts and circumstances giving rise to these ST Revisions are that the Petitioner M/s. Kalinga Brooms, Ogalapada, Janala is engaged in manufacturing of brooms and for the said purpose the Petitioner purchases the raw materials, i.e., broomsticks, plastic hangles, wires etc. The Sales Tax Officer, Puri II Circle assessed the Petitioner for the year 2000-02 by imposing tax @ 12% on brooms under unspecified item treating the same as finished product of the Small Scale Industrial Unit, which had been availing the tax benefit under Industrial Police Resolution 1989. The Assessing Officer observed that the Assessee-Petitioner had purchased raw materials on the strength of 1-D form and From C during the relevant period. Challenging the said order, the Petitioner filed appeal before the Assistant Commissioner of Sales Tax which was dismissed and the order of the Assessing Officer was affirmed. Thereafter the Petitioner filed Second Appeal before the Orissa Sales Tax Tribunal, which also did not accept the contention of the Petitioner that the broomsticks and brooms both are not two different commercial and marketable commodities. Considering the fact that in order to manufacture brooms the broomsticks are used as raw materials, the Tribunal came to the conclusion that broomstick and broom are not one and the same item as claimed by the Petitioner. According to the Tribunal, broomsticks were raw materials and brooms were finished product. 4. Mr. J.B. Sahoo, learned Counsel for the Petitioner submitted that the Petitioner has paid the purchase tax on the purchased turnover of broomsticks; once the purchase tax has been paid under the Orissa Sales Tax Act ( hereinafter called " the OST Act" ), same is not liable to be imposed on the sale turnover. He further submits that since there is no difference or distinction between broomstick and broom, the Petitioner is not liable to pay any tax on the sale of brooms. 5. He further submits that since there is no difference or distinction between broomstick and broom, the Petitioner is not liable to pay any tax on the sale of brooms. 5. Learned Counsel is for the Revenue submitted that both the commodities are two different commercial commodities and in common parlance they are not understood as same commodity. He submitted that the Petitioner being an SSI Unit has availed the benefit of IPR 1989 and hence, it is not entitled to get any tax exemption on the sale of brooms, which is a finished product. Therefore, it is not possible on the part of the Petitioner to take a contrary stand that brooms are similar to broomsticks. He further submitted that there is no material to interfere with the findings reached by the Tribunal and the question of law framed is no longer res intergra and does not arise for consideration. 6. We have considered the rival submissions of the learned Counsel for the parties and perused the record. 7. Admittedly, the factual submissions made by the learned Counsel for the Revenue remain un-rebutted. In view of the fact that the Petitioner had taken the benefit of IPR 1989 and purchased the raw materials at concessional rate of tax, it cannot be said even by any stretch of imagination that broomsticks have not suffered the process of manufacturing and it is not a different commercial item than the brooms. Thus, we do not see any reason to take a view contrary to the view taken by the Tribunal. 8. In view of the above, the question raised is answered in the negative, i.e., in favour of the Revenue and against the Assessee. The ST Revision petitions are thus disposed of.