Continuing exemption under earlier sales tax notification remained available where later rate reduction did not expressly supersede it.

S.R.O. No. 1003 of 1991 continued to apply to small-scale industrial units purchasing rubber for manufacture, because it granted exemption subject to specified conditions and was not expressly superseded by S.R.O. No. 372 of 1992. The later notification only provided a reduced tax rate for rubber used in making tyres, tubes and flaps and did not refer to or displace the earlier exemption. On that basis, the earlier notification remained operative and the assessee remained entitled to its benefit.

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Issues: Whether the assessee was entitled to the benefit of S.R.O. No. 1003 of 1991 notwithstanding the subsequent S.R.O. No. 372 of 1992.

Analysis: S.R.O. No. 1003 of 1991 granted exemption on purchase of rubber by small-scale industrial units subject to specified conditions, including levy of tax on the manufactured products under the Kerala General Sales Tax Act or the Central Sales Tax Act, 1956. The subsequent S.R.O. No. 372 of 1992 granted a reduction in tax rate for purchase of rubber for manufacture of tyres, tubes and flaps, but did not expressly supersede S.R.O. No. 1003 of 1991. Since the later notification did not refer to or displace the earlier exemption, the earlier notification continued to operate.

Conclusion: The assessee was entitled to the benefit of S.R.O. No. 1003 of 1991.

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