State sales tax exemption notification does not automatically extend to Central Sales Tax liability

An exemption notification issued under section 8-A of the Karnataka Sales Tax Act, 1957 applied only within that Act and only to the items and period specified in the notification. A dealer has no vested right to claim tax exemption, and relief granted under one taxing statute cannot be read as automatically extending to liability under the Central Sales Tax Act, 1956. Any effect of the State exemption on Central Sales Tax liability would have to be examined separately and could not be decided in the writ petitions. The notification therefore did not entitle the petitioners to exemption from Central Sales Tax.

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Issues: Whether a notification issued under section 8-A of the Karnataka Sales Tax Act, 1957 granting exemption from tax under that Act could be construed to extend the same exemption to liability under the Central Sales Tax Act, 1956.

Analysis: The exemption notification operated only within the scope of the Karnataka Sales Tax Act, 1957 and was limited to the items and period specified in it. A dealer has no vested right to claim exemption from tax, and a notification granting relief under one statute cannot be read as automatically governing liability under a different enactment. Any consequence of the exemption on liability under the Central Sales Tax Act, 1956 would have to be pursued in separate proceedings and could not be decided in these writ petitions.

Conclusion: The notification under the Karnataka Sales Tax Act, 1957 did not entitle the petitioners to exemption from tax under the Central Sales Tax Act, 1956.

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