Superseded exemption notification not revived by later cancellation; earlier tax exemption remained unavailable.

Cancellation of a later exemption notification did not revive an earlier notification that had already been superseded under the Tamil Nadu General Sales Tax Act, 1959. The governing principle applied was that a later notification's prospective cancellation does not, by itself, restore an earlier exemption unless revival is expressly provided for or the earlier notification never ceased to operate. The later notification therefore retained its legal effect until cancellation, and the earlier exemption remained unavailable. The challenge to the levy and exemption structure accordingly failed, leaving the tax demand unaffected.

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Issues: Whether cancellation of a later exemption notification revived the earlier superseded notification, and whether the later notifications could be treated as invalid on the ground that they could not coexist with the earlier exemption.

Analysis: The exemption under the Tamil Nadu General Sales Tax Act, 1959 was first granted by one notification, then restricted by a later notification, and the later notification was subsequently cancelled prospectively. The governing principle applied was that cancellation or quashing of a later notification does not automatically revive an earlier notification that had already been superseded, unless revival is expressly provided for or the earlier notification had never effectively ceased to operate. The later cancellation did not erase the legal existence of the superseding notification from inception, and there was no basis to infer an intention to keep the earlier exemption alive after supersession. The contention that the two later notifications could not stand together also failed because the earlier notification was not revived by the cancellation of the superseding one.

Conclusion: The earlier exemption notification did not revive, and the challenge to the later levy and exemption structure was rejected.

Final Conclusion: The writ petitions failed because the cancellation of the later notification did not restore the earlier exemption, leaving the impugned tax demand unaffected.

Ratio Decidendi: Where a later notification has superseded an earlier one, its subsequent prospective cancellation does not, by itself, revive the earlier notification.

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