Sales tax deferral benefit for manufactured products cannot be narrowed by a certificate preamble or recorded company name change.

A sales tax deferral scheme was construed by reading the Government order, eligibility certificate, notification and agreement together. On that reading, the concession attached to products manufactured by the eligible unit and was not confined to the single product mentioned in the certificate's preamble. A duly recorded company name change in the Registrar of Companies and statutory records could not be used to deny the benefit. In the absence of any factual basis negating eligibility, a demand for immediate repayment of the deferred amount with interest was held unsustainable.

---

---

Issues: Whether the petitioner was entitled to the benefit of sales tax deferral for all products manufactured by the unit under the Government order, eligibility certificate and notification, and whether the demand notice and the appellate order denying that benefit could be sustained.

Analysis: The deferral scheme, the eligibility certificate and the related notification were read together with the agreement between the parties. Their language showed that the benefit attached to the sale of products manufactured by the unit and was not confined to a single product mentioned in the preamble of the certificate. The materials also showed that the company's name change had been duly reflected in the records of the Registrar of Companies and the statutory authorities, so the altered name could not be used to deny the granted benefit. In the absence of any factual dispute negating eligibility, the demand for immediate repayment of the deferred amount with interest had no foundation.

Conclusion: The petitioner was entitled to the deferral benefit for its manufactured products, and the demand notice and the Tribunal's order denying that benefit could not be sustained.

Final Conclusion: The demand was quashed and the petitioner obtained relief against further recovery proceedings.

Ratio Decidendi: Where a tax deferral scheme grants benefit to products manufactured by an eligible unit, the benefit cannot be curtailed by reading the eligibility certificate narrowly or by relying on a duly recorded change in the company's name to deny the concession.

---