Prospective operation of exemption notifications bars retrospective tax relief absent clear language extending the benefit backward.

An exemption notification under the Karnataka Sales Tax Act operated only from the date expressly stated in the notification, and could not be extended backwards to an earlier part of the assessment year. Because the text contained no clear language conferring retrospective effect, the claimed benefit from 1 April 1999 was untenable. The cited precedent on assessment-year operation of notifications was found inapplicable on the facts. The result was that the exemption remained prospective only and no retrospective relief was available.

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Issues: Whether the exemption notification issued under the Karnataka Sales Tax Act operated prospectively from its date of issue or could be applied retrospectively to an earlier part of the assessment year.

Analysis: The notification expressly stated that the benefit was available with immediate effect from 1 January 2000. The assessee sought to extend that benefit back to 1 April 1999, but there was no indication in the notification of any retrospective operation. In the absence of express language making the exemption effective from an earlier date, the notification could not be construed to cover a prior period. The cited precedent on assessment-year operation of notifications was held inapplicable on the facts.

Conclusion: The exemption notification was prospective only and did not confer a retrospective benefit on the assessee.

Final Conclusion: The revision petition failed because the assessee's claim to retrospective exemption was untenable in law and the orders of the authorities below required no interference.

Ratio Decidendi: An exemption notification that states it is effective from a specified date operates prospectively from that date and cannot be given retrospective effect in the absence of clear language to that effect.

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