Completed sales tax exemption cannot ordinarily be withdrawn retrospectively after it has been fully acted upon.

A sales tax exemption that has been validly granted, amended in the assessee's favour, and fully acted upon for its operative period is ordinarily not liable to retrospective review or withdrawal after the benefit has been availed. A later attempt to reopen the settled exemption years after expiry, without prior notice or any established allegation of fraud, is treated as unjustified. The operative principle is that completed exemption benefits should not be made conditional or withdrawn retrospectively in the absence of a legally sustainable basis.

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Issues: Whether sales tax exemption, once granted and acted upon, could be reviewed and withdrawn after the exemption period had expired.

Analysis: The exemption had been granted by the competent authority, amended in the assessee's favour, and acted upon for the entire period of its operation. The impugned order sought to reopen the settled exemption years later and to make the earlier benefit conditional, without any prior notice or established allegation of fraud. The Court followed the principle that a completed exemption, long since availed of, cannot ordinarily be revisited retrospectively and that such a belated review is unjustified.

Conclusion: The retrospective review and withdrawal of the exemption was impermissible and was set aside in favour of the assessee.

Final Conclusion: The writ petition succeeded, and the impugned orders were quashed.

Ratio Decidendi: An exemption certificate that has been validly granted and fully acted upon cannot be reviewed or withdrawn retrospectively after the benefit has been availed, absent fraud or a legally sustainable basis.

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