Judgment :- C.N. Ramachandran Nair, Judge. 1. The question raised is whether the petitioner is entitled to concessional rate of tax on purchase of natural rubber used for rubber backing of polypropalin rubber mats done on job work basis. We have heard Sri. Anilkumar, counsel appearing for the petitioner and overnment Pleader Sri. Mohammed Rafiq for respondent. 2. During 2004-05, petitioner undertook the work of rubber backing of polypropalin rubber mats for another manufacturer. Rubber backing done by the petitioner is admittedly an industrial activity involving manufacturing process. Petitioner claimed concessional rate of tax at 6% on the purchase turnover of rubber used in the job work as above under notification, S.R.O.No.1091/99. Even though in the original assessment completed for 2004-05 concessional rate was granted, the same was later withdrawn by making a tax escaping assessment under S.19(1) of the K.G.S.T. Act for the reason that a job worker who is not engaged in the manufacturing of products is not entitled to concession. The order of disallowance was confirmed in two levels appeals and hence this Revision is filed before this Court against the order of the Tribunal. Relevant portions of the notifications are extracted hereunder: “S.R.O.No.1091/99.—In exercise of the powers conferred by S.10 of the Kerala General Sales Tax Act, 1963 (Act 15 of 1963) and in supersession of all the earlier notifications (except the notification issued in G.O. (P) 155/93/TD dated 3rd November, 1993) issued under S.10 of the Kerala General Sales Tax Act which are in force as on the 31st day of December 1999, the Government of Kerala, having considered it necessary in the public interest so to do, hereby;- 1. make a reduction in the rate of tax payable under the said Act,- (1) on the turnover of sale or purchase, as the case may be, of goods specified in column (2) of Schedule I from the rate specified in column (3) to the rate specified column(4) thereof, against each. Xxx xxx xxx Xxx xxx xxx SCHEDULE I Persons, the rate of tax on the turnover of whose sales or purchase as the case may be of goods, is reduced under sub-clause (2) of Clause 1 Sl. No. Description of Person/unit Description of goods and transaction Reduced rate of tax (per cent) Conditions 1 XX XX XX XX 2. Xxx xxx xxx Xxx xxx xxx SCHEDULE I Persons, the rate of tax on the turnover of whose sales or purchase as the case may be of goods, is reduced under sub-clause (2) of Clause 1 Sl. No. Description of Person/unit Description of goods and transaction Reduced rate of tax (per cent) Conditions 1 XX XX XX XX 2. Rubber based industrial units Turnover of purchase of rubber for use in the manufacture of rubber products within the State 6 Nil Explanation: - Rubber products for the purpose of this notification shall mean any goods manufactured, utilizing rubber in any form as one of the raw materials but shall not include any form of rubber taxable at the point of last purchase in the State or which are subjected to processing by mixing with chemicals, gas, fumigation or any other similar process to make any compound of rubber. 2. There is no dispute that the petitioner was engaged in job work for manufacture of Rubber backed Polypropalin mats. Under contract with the manufacturer, the petitioner gave rubber backing to polypropalin mats, supplied by the manufacturer. If the manufacturer had purchased rubber, supplied the same to the petitioner and entrusted only pure labour work of rubber backing in petitioner’s factory, then the manufacturer who purchased the rubber would have got concessional rate on the purchase turnover of rubber under the very same notification above stated. The question is whether the benefit of concessional rate of tax should be declined to the job worker when he purchased the rubber on his own account and supplements the manufacturing activity by doing job work for the manufacturer. In fact, the ultimate product manufactured after the rubber backing done by the petitioner is rubber backed polyproplain mats. Therefore, in effect the full manufacturing of this product was carried out in two industrial units and petitioner’s industrial unit is the second one where rubber backing is given to the polypropalin mats to make it the final product though petitioner did it as a job work. What is required of the notification is that the purchase should be by the rubber based industrial unit and the purchased rubber should be used in the manufacture of rubber products within the State. Rubber product as defined under Explanation to the notification takes in any goods manufactured with rubber in any form as one of the raw materials. What is required of the notification is that the purchase should be by the rubber based industrial unit and the purchased rubber should be used in the manufacture of rubber products within the State. Rubber product as defined under Explanation to the notification takes in any goods manufactured with rubber in any form as one of the raw materials. By virtue of this Explanation, when the polypropalin mats is given rubber backing it becomes a rubber product, no matter it is predominantly a polypropalin product. So much so, petitioner satisfies both the conditions in the notification in as much as it is an industrial unit purchasing the rubber and though as a job worker, it carries out industrial activity to make the product a rubber product within the meaning of the notification. We feel the denial of concessional rate to the petitioner will defeat the very purpose of notification which is promotion of rubber based industries in the State. We, therefore, hold that the petitioner is entitled to concessional rate for the purchase of rubber under the notification for the relevant year and accordingly the revision case is allowed by vacating the order of the Tribunal confirming the re-assessment and by restoring the original assessment at concessional rate of tax on the purchase turnover of rubber used in rubber backing work done by the petitioner for others.