Concessional sales tax notification can be validly limited later where the statutory power permits modification of the earlier benefit.

A concessional sales tax benefit granted to promote new rubber-based industries was held not to create a permanent entitlement. The later notification issued under the Kerala General Sales Tax Act, 1963 validly modified the earlier concession and confined the benefit to a further maximum period of two years, thereby limiting the overall concession period. The impugned circulars were treated as reflecting that corrected statutory position. The claim that the original concession continued indefinitely was rejected, and the challenge based on discrimination under Articles 14 and 301 of the Constitution was not accepted.

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Issues: Whether the earlier concessional sales tax notification continued to operate, and whether the later notification and consequential circulars validly limited the concession to a further fixed period.

Analysis: The concession granted by the 1988 Government Order was intended to encourage new rubber-based industries and was not meant to create a permanent tax benefit. The later notification, issued under section 10 of the Kerala General Sales Tax Act, 1963, was treated as a valid exercise of power to modify the earlier concession. Read in the factual background of the scheme, the later notification was not ambiguous and confined the benefit to a maximum further period of two years, thereby limiting the overall concession period. The contention that the earlier concession continued indefinitely was rejected, and the court held that the impugned circulars merely reflected the corrected statutory position. The argument based on discrimination under articles 14 and 301 of the Constitution of India was not accepted.

Conclusion: The later notification validly superseded and limited the earlier concession, and the petitioners were not entitled to a declaration that the concessional rate continued indefinitely.

Ratio Decidendi: Where a concession granted to promote new industries is later modified under the statutory power to vary or cancel notifications, the later notification prevails and validly limits the concession for the period specified by it.

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