Tax remission discretion upheld where refusal was based on relevant public interest considerations and no mala fides was shown.

The Government's refusal to remit purchase tax under the Madhya Pradesh Sugarcane (Purchase Tax) Act was upheld because remission is an administrative power to be exercised only where public interest and the statutory conditions are satisfied. The Court held that such a decision can be challenged only for mala fides, discrimination, or reliance on irrelevant considerations, and that the absence of recorded reasons does not by itself invalidate the refusal. As the materials did not show that the factory had established the conditions for remission, the refusal was justified and not liable to interference.

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Issues: Whether the Government's refusal to grant remission of purchase tax under section 16 of the Madhya Pradesh Sugarcane (Purchase Tax) Act, 1961 was arbitrary or illegal and liable to be quashed.

Analysis: The power to remit tax under section 16 is an administrative power exercisable if the Government is satisfied that remission is necessary in public interest to assist factories continuously running into loss due to under-crushing or purchase of cane yielding low sugar recovery. Such an order can be questioned only on grounds such as mala fides, discrimination, or reasons not germane to the statutory power. The mere fact that the order did not record reasons did not render it invalid, and the materials before the Court showed that the petitioner had not satisfied the Government that the statutory conditions were met.

Conclusion: The refusal to grant remission was held to be justified and not liable to be interfered with.

Ratio Decidendi: An administrative decision under a tax-remission provision is valid if taken on relevant considerations in public interest, and it is not invalid merely because reasons are not recorded, unless mala fides, discrimination, or irrelevant considerations are shown.

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