Deduction for purchases from exempted units upheld under Punjab sales tax law, following binding Supreme Court interpretation.

Goods purchased from an exempted unit were treated as standing on the same footing as goods on which tax had been paid for purposes of the deduction provision under the Punjab sales tax law. The court construed the deduction scheme in light of the exemption structure and followed the earlier Supreme Court affirmation of that interpretation as binding. A proposed review petition did not justify departing from that authority, and the deduction was held allowable.

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Issues: Whether goods purchased from an exempted unit were covered by the deduction provision for goods subject to tax at the first stage under the Punjab sales tax law.

Analysis: The deduction provision was construed in the light of the exemption scheme. Goods exempted from tax were held to stand on the same footing as goods on which tax had been paid for the purpose of the relevant deduction, and the prior Supreme Court affirmation of this interpretation was treated as binding. The mere proposed filing of a review petition did not justify ignoring that decision.

Conclusion: The deduction was allowable, and the assessee succeeded.

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