Raw material tax exemption for multiple units sustained as the Supreme Court found no error in the High Court's approach.

Exemption from tax on purchases of raw material under the Rajasthan Sales Tax Act was claimed for all units of a staged industrial set-up, including an additional plant established after registration as a 100% Export Oriented Unit. The Tribunal confined the benefit to the newly established 28 MT unit and denied it for the earlier 14 MT capacity, but the High Court extended the notification to all units. The Supreme Court found no error in that approach and declined interference, with the Revenue's challenge failing and the exemption benefit sustained.

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Issues: Whether the respondent was entitled to exemption from tax on purchases of raw material for all its units under the notification issued under Section 4(2) of the Rajasthan Sales Tax Act, 1954, and whether the Commissioner's interference with the assessment order was justified.

Analysis: The respondent had established units in stages and later set up an additional plant after obtaining registration as a 100% Export Oriented Unit. The Tribunal granted exemption only to the newly established 28 MT unit and declined it for the earlier 14 MT capacity, while the High Court extended the benefit of the notification to all the units. The challenge before the Supreme Court did not disclose any error in the High Court's approach warranting interference.

Conclusion: The Revenue's challenge failed, and the exemption benefit as granted by the High Court stood sustained.

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