Sales tax exemption timing depends on notification-based industrial unit status and the relevant production date.

Eligibility for sales tax exemption under the section 4-A notification turned on the notification's own definition of "industrial unit" and the relevant production date. The notification required permanent registration with the Directorate of Industries before the unit could be treated as an industrial unit, and the "date of starting production" had to be read consistently with that status. On the stated facts, permanent registration was obtained only on 11 September 1986, while production commenced on 3 March 1986 and the first sale occurred on 5 March 1986. The later statutory definition relied on by the High Court was inapplicable to the relevant period, so the exemption ran for six years from 5 March 1986.

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Issues: Whether the appellant was entitled to sales tax exemption for six years from the date of first sale on 5 March 1986, rather than for four years from 1 November 1985, under the exemption notification issued in relation to section 4-A of the Uttar Pradesh Sales Tax Act, 1948.

Analysis: The relevant notification defined "industrial unit" by reference to permanent registration with the Directorate of Industries and to the conditions specified in the notification. It also linked "date of starting production" to the meaning assigned in the explanation to section 4-A of the Uttar Pradesh Sales Tax Act, 1948. On the facts, the appellant obtained permanent registration only on 11 September 1986 and became an industrial unit within the notification from that date, while production for the relevant unit commenced on 3 March 1986 and the first sale was on 5 March 1986. The later statutory definition relied upon by the High Court was inapplicable to the relevant period, and the date of starting production could be applied only after the appellant satisfied the notification's definition of industrial unit.

Conclusion: The appellant was entitled to exemption for six years from 5 March 1986, and not for four years from 1 November 1985.

Ratio Decidendi: For exemption under the notification, the operative date must be determined by the notification's own definition of "industrial unit" and the relevant production date cannot be applied independently of that status.

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