Special sales tax exemption for specified units is not a general tax exemption under section 8(2A).

A special sales tax exemption confined to specified goods manufactured by identified newly set up industrial units for a fixed period was not an exemption from tax generally under section 8(2A) of the Central Sales Tax Act. The provision applies only where goods are exempt as a class, while the statutory explanation excludes exemptions operating in specified circumstances or subject to specified conditions. The 1972 amendment was treated as clarificatory and did not alter that principle. On that basis, the assessee could not claim the benefit of section 8(2A).

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Issues: Whether a special exemption granted to specified goods manufactured by specified industrial units for a limited period constitutes an exemption from tax generally within the meaning of section 8(2A) of the Central Sales Tax Act, and whether the 1972 amendment altered the governing concept.

Analysis: The notification granted exemption only to identified goods manufactured by identified newly set up undertakings and only for a fixed period. Such relief was not a general exemption available to the goods as a class across the State, but a special concession tied to specified units, specified goods, and a specified stage of industrial development. Under section 8(2A), both before and after amendment, exemption is available only where the goods are exempt from tax generally, and the statutory explanation excludes exemptions operating in specified circumstances or under specified conditions. The amendment was understood as clarificatory and not as changing the underlying principle. The prior authorities relied on by the respondent did not support a contrary conclusion.

Conclusion: The exemption was not one from tax generally, and the assessee was not entitled to the benefit of section 8(2A) of the Central Sales Tax Act. The appeal succeeded on this point.

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