Exemption certificate coverage extends to additional sales tax on turnover-based levies for eligible industrial units.

An eligible small-scale industrial unit holding an exemption certificate under S.R.O. No. 1729/1993 was treated as entitled to exemption from additional sales tax under section 5D of the Kerala General Sales Tax Act. The exemption notification covered tax on the sales turnover of goods manufactured and sold by eligible units, and its scheme was read as extending to turnover-based imposts such as surcharge and additional sales tax. The later introduction of section 5D did not place that levy outside the existing exemption certificate, so the exempted amount had to be adjusted against the certified tax exemption limit.

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Issues: Whether the petitioner, an eligible small-scale industrial unit holding an exemption certificate issued under S.R.O. No. 1729/1993, was entitled to exemption from additional sales tax payable under section 5D of the Kerala General Sales Tax Act.

Analysis: The exemption notification granted relief on tax payable on the sales turnover of goods manufactured and sold by eligible units and also contemplated exemption for surcharge payable under the Kerala Surcharge on Taxes Act, 1957. The additional sales tax under section 5D was treated as a levy on the sales turnover and, though distinct in form, was regarded as falling within the scope of the exemption already granted. The later introduction of section 5D did not take the levy outside the cover of the existing exemption certificate, and the exempted amount was to be adjusted against the certified tax exemption limit.

Conclusion: The petitioner was entitled to exemption from additional sales tax under section 5D, and the respondents were bound to grant the exemption and set it off against the amount certified for tax exemption.

Final Conclusion: The writ petition succeeded on the scope of the exemption notification, with additional sales tax treated as covered by the existing exemption certificate for the eligible unit.

Ratio Decidendi: Where an exemption notification grants relief on tax payable on the sales turnover of eligible goods, a later additional levy on the same turnover may be treated as covered by the exemption if the notification's language and scheme show an intention to extend the benefit to such turnover-based imposts.

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