Eligibility certificate exemption cannot be refused on mere change of opinion absent fraud, misrepresentation, suppression, or breach of conditions.

An eligibility certificate and related tax exemption, once granted after due consideration, could not be withdrawn or refused on a later change of opinion alone. The governing scheme allowed cancellation only on recognised grounds such as fraud, misrepresentation, suppression of material facts, false information, or breach of conditions, and none was shown. The underlying question whether the activity amounted to manufacture was treated as debatable, making the earlier departmental view a possible view. The refusal to renew the benefit was therefore unsustainable.

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Issues: Whether renewal of an eligibility certificate and consequent tax exemption could be refused merely on a belated change of opinion, in the absence of fraud, misrepresentation, suppression, or breach of conditions, and whether the earlier departmental view was a possible view.

Analysis: The eligibility certificate had been granted after due consideration and was renewed earlier. The later refusal rested only on a revised opinion that the activity did not amount to manufacture. The governing exemption scheme permitted cancellation or denial only on recognised grounds such as violation of conditions, false information, fraud, misstatement, or suppression. No such ground was shown. The dispute on whether the process amounted to manufacture was treated as debatable, and the earlier departmental view granting eligibility was held to be a possible view. Mere change of opinion at a later stage could not justify withdrawal of the benefit already granted.

Conclusion: Renewal could not be declined merely on change of opinion, and the impugned orders refusing the benefit were unsustainable.

Ratio Decidendi: An eligibility or exemption benefit once granted after due consideration cannot be withdrawn or refused on a mere subsequent change of opinion unless the statute permits it on established grounds such as fraud, misrepresentation, suppression, or breach of conditions.

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