Sales tax exemption and promissory estoppel issue remitted for fresh consideration after withdrawal notification and eligibility certificate dispute.

Sales tax exemption was examined in the context of a pre-existing eligibility certificate, an earlier exemption regime, and a later notification withdrawing the benefit. The Tribunal had not properly considered the effect of the eligibility certificate or the assessee's pleaded case on promissory estoppel, and the factual material relevant to that issue was incomplete. The common appellate order was set aside and the controversy was remitted for fresh adjudication, with the exemption and promissory estoppel questions left open for reconsideration and limited interim protection granted.

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Issues: Whether the Tribunal's order denying sales tax exemption should be set aside and the matters remanded for fresh consideration in light of the eligibility certificate and the subsequent notification withdrawing the exemption.

Analysis: The assessee held an eligibility certificate issued by the competent authority for the relevant period, and the assessments had originally allowed the exemption. The reassessment and appellate orders proceeded on the basis of a later notification withdrawing the benefit, but the Court found that the Tribunal had not properly considered the effect of the pre-existing eligibility certificate, the earlier notification regime applicable to the assessee, and the pleaded question of promissory estoppel. The Court also noted that the factual foundation relevant to promissory estoppel had not been fully placed and that the assessee should be permitted to produce additional materials before the Tribunal.

Conclusion: The Tribunal's order was set aside and the matter was remanded for fresh decision; the issue of exemption and promissory estoppel was left open for reconsideration.

Final Conclusion: The tax revision matters were allowed in part by setting aside the common appellate order and restoring the controversy to the Tribunal for fresh adjudication, with interim protection granted for a limited period.

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