Tax relief under a rehabilitation scheme requires government consideration, but does not create an enforceable right to exemption.

A rehabilitation scheme direction to consider tax relief did not create an automatic or enforceable right to extension of sales tax exemption or concessional central sales tax. The Government had already examined and ? need English only. Let's craft proper. The Government had already examined the claim and rejected it, and the earlier writ proceedings had left the petitioner to pursue the matter before the Government. A prior Division Bench decision had also rejected the same claim for similarly placed assessees. The consequential assessment notices were not interfered with, as they had already resulted in final assessment orders.

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Issues: Whether the petitioner was entitled to extension of sales tax exemption and concessional central sales tax up to 31 March 2006 and to quashing of the consequential assessment notices.

Analysis: The rehabilitation scheme only required the Government to consider extension of the concession; it did not confer an automatic or enforceable right to exemption. The Government had already examined the claim and rejected it, and the earlier writ proceedings had ended by relegating the petitioner to approach the Government. The Court also noted that a Division Bench had already answered the same claim against similarly placed assessees, and that the impugned notices had in any event culminated in final assessment orders.

Conclusion: The petitioner was not entitled to the claimed extension of exemption or to interference with the notices and assessment proceedings.

Ratio Decidendi: A direction in a rehabilitation scheme to consider grant of tax relief does not, by itself, create a vested or enforceable entitlement to the concession.

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