ORDER C. N. RAMACHANDRAN NAIR :- The revisions are filed challenging the orders of the Sales Tax Appellate Tribunal, Additional Bench, Palakkad confirming disallowance of petitioner's claim for exemption on the purchase of river sand under Notification S.R.O. No. 1090 of 1999. The petitioner is a registered dealer, which was engaged in manufacture and supply of concrete poles to Kerala State Electricity Board. The petitioner purchased sand from unregistered dealers in Kerala, which was used in the manufacture of electric poles for supply to Kerala State Electricity Board. Since suppliers were not registered dealers and since sand purchased by the petitioner and used in the manufacture of electric poles have not suffered tax, the assessing officer, levied tax under section 5A of the Kerala General Sales Tax Act, 1963. Appeals filed were dismissed by the two appellate authorities, including the Tribunal and therefore the petitioner approached this court with these revisions filed under section 41 of the Kerala General Sales Tax Act. We have heard counsel for the revision - petitioner and Government Pleader appearing for the respondent. Clause 5 of the First Schedule of the Notification S.R.O. No. 1090/1999 under which exemption is claimed is as follows : "Schedule I Dealers whose turnover of sale or purchase is exempt under sub-clause (1) of clause I Sl. No. Name of dealer Turnover which is exempted Conditions and restrictions (1) (2) (3) (4) 1. ... ... ... 2. ... ... ... 3. ... ... ... 4. ... ... ... 5. Any dealer Turnover of sale of river sand within the State The sand is for consumption within the State 6. ... ... ..." The question to be considered is whether the conditions of notification are satisfied in petitioner's case. Counsel for the petitioner rightly contended that exemption under the above clause of the notification applies to the item as such, irrespective of whether proposal for levying tax is in the hands of the seller or purchaser. The Government Pleader, on the other hand, submitted that the condition for granting exemption is consumption within the State and according to him consumption in the manufacture and sale of goods is not covered by the notification. We are inclined to accept the claim of the petitioner that benefit of notification applies to the product, irrespective of whether proposal for assessment is on the seller or on the purchaser. We are inclined to accept the claim of the petitioner that benefit of notification applies to the product, irrespective of whether proposal for assessment is on the seller or on the purchaser. In other words, exemption under the notification is available to dealers, who are liable to pay tax under section 5A also. All what is required to be satisfied is that the sand purchased is for "consumption" within the State. The remaining question for consideration is whether there is consumption by the petitioner in this case or in other words whether use of sand in the manufacture of concrete poles is consumption. In this context, it is worthwhile to refer to clause (a) of section 5A(1) of the KGST Act which is as follows : "Consumes such goods in the manufacture of other goods for sale or otherwise." It is very clear from the above provision that use in manufacture is accepted as consumption in manufacture and so much so, use of sand in the manufacture of concrete poles by the petitioner for supply to Kerala State Electricity Board is nothing but consumption in manufacture. The only other condition under the notification is that such consumption in manufacture should take place within the State on which there is no controversy. The purpose of exemption, in our view, is essentially to promote the construction industry in the State. We, therefore, allow the revision by vacating the orders of the Tribunal and that of the lower authorities and by quashing revised assessment on this issue.