Starting production for tax exemption turns on actual commencement and pleadings, not a later power connection or new factual theory.

For exemption under section 4-A, the date of starting production depended on the later of first raw material purchase and installation of power connection where power was necessary. On the facts, the unit had already begun manual production, purchased raw material on 1 March 1985, and made its first sale on 30 March 1985, so power connection was not essential to commencement of production. The claim to a five-year exemption also failed because the required factual foundation that capital investment exceeded the statutory limit on the relevant dates was not specifically pleaded before the authority and could not be raised for the first time in writ proceedings.

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Issues: Whether the date of starting production for purposes of exemption under section 4-A was the date of first purchase of raw material or the later date of installation of power connection, and whether the petitioners were entitled to a five-year exemption period on the footing that their capital investment exceeded the statutory limit on the relevant date.

Analysis: Under explanation (ii) to sub-section (2) of section 4-A, the date of starting production is the later of the first purchase of raw material and the installation of power connection where power is needed. The factual inquiry showed that the unit had begun manual production in March 1985, had purchased raw material on 1 March 1985, and had effected first sale on 30 March 1985. The Court held that power connection was not essential for the unit to commence production, because production had in fact been carried on without it. On the exemption question, the petitioners had not specifically pleaded before the authority that even on 1 March 1985 or 30 March 1985 their capital investment exceeded the prescribed limit, and the new factual theory could not be entertained for the first time in writ proceedings. No error of law or jurisdictional infirmity was shown in the committee's finding.

Conclusion: The date of starting production was 1 March 1985, the exemption period commenced from 30 March 1985, and the claim to a five-year exemption was not established.

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