- (1.) The respondent-assessee manufactures vegetable ghee from ground-nut oil. The groundnut oil is mixed with acids and chemicals in order to purify and refine it. The residue left, after the removal of the refined portion, is sold to the soap manufacturers. According to the assessee the turnover of the sale of residue was taxable at one per cent on the basis that the residue was still groundnut oil, The Sales Tax Officer rejected this contention and he held that the residue was oil of a different character being not edible and was taxable at six per cent. The view taken by the Sales Tax officer was upheld in the appeal. The assessee went in revision and the revisional authority set aside the orders of the Sales Tax Officer and the appellate authority and came to the conclusion that the residue, in its nature and character, was groundnut oil with greater impurities than the original oil. It was held that the residue was taxable as groundnut oil at one per cent. At the instance of the Commissioner, Sales Tax, the following question was referred for the opinion of the High Court : "Whether, on the facts and in the circumstances of the case the additional Judge (Revisions) was legally justified in holding the residual oil as groundnut oil simpliciter, even when it had undergone change in its properties by the admixture of chemicals and acids -the High Court following the judgment of this Court in Tungabhadra industries Ltd. v. Commercial Tax Officer [1960] 11 STC 827, came to the conclusion that the residue left, after going through the process of acids and chemicals, continues and remains to be the groundnut oil and is taxable at one per cent. We agree with the reasoning and the conclusions reached by the High Court. There is no merit in this appeal and the same is dismissed with no order as to costs.;