Sales tax exemption depends on actual manufacturing during the claimed period, not on continuous operation for the full exemption term.

A sales tax exemption under a notification issued under section 8-A of the Karnataka Sales Tax Act, 1957 could not be refused merely because the industrial unit did not continue for the full exemption period. The operative question was whether the unit actually carried on manufacturing during the period for which exemption was claimed, and the benefit was not made conditional on the unit's existence for the entire four years. The Court left the factual verification to the respondents and required them to examine the evidence of actual manufacture at Electronic City. If manufacture was proved for the claimed period, exemption and the certificate were to be granted for that period.

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Issues: Whether a sales tax exemption under the notification issued under section 8-A of the Karnataka Sales Tax Act, 1957 could be denied merely because the industrial unit had not remained in operation for the full exemption period, and whether the petitioner was entitled to exemption for the period during which manufacturing activity was actually carried on.

Analysis: The exemption notification granted relief for a fixed period of four years, but it did not make the benefit conditional upon the unit continuing in existence for the entire period. The relevant consideration was whether the unit had functioned during the period for which exemption was claimed. The Court declined to decide the factual controversy itself and left it to the respondents to verify the evidence produced by the petitioner regarding actual manufacture at Electronic City during the claimed period.

Conclusion: Exemption could not be denied on the ground that the unit did not continue for four years; if the petitioner established that manufacturing activity was carried on from 8 February 1992 to 6 November 1993, exemption and the necessary certificate were to be granted for that period.

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