Tax deferment for new industrial units does not extend to purchase tax on raw materials under the scheme wording.

A sales tax deferment scheme for new industrial units was confined to tax on products manufactured by those units and did not extend to purchase tax on raw materials used in production. The court read the Government Order according to its plain language and held that a beneficial interpretation cannot enlarge a taxing concession beyond the express wording of the notification. It further noted that the scheme was quantified by fixed capital cost and the prescribed period, confirming that its scope was limited to the manufactured products alone. The deferment therefore did not apply to purchase tax on raw material, and the claim failed in favour of the Revenue.

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Issues: Whether the sales tax deferment granted under G.O. Ms. No. 117 dated 17-3-1993 for products manufactured in new industrial units extends to purchase tax payable on raw material used in the manufacturing process.

Analysis: The scheme in the Government Order granted deferment of sales tax on the products manufactured in new industrial units, quantified by reference to the fixed capital cost and the prescribed period. The language of the scheme was held to be clear and confined to tax on the manufactured products, and not to tax on the purchase of raw material. The Court held that beneficial construction cannot be used to enlarge a taxing concession beyond the plain words of the notification, and a court cannot rewrite the scheme to include a benefit not expressly granted.

Conclusion: The deferment did not cover purchase tax on raw material. The issue was decided against the petitioners and in favour of the Revenue.

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