Sales tax incentive scheme limited to new export-oriented units; long-established units cannot claim refund or exemption merely for export status.

A Government Order granting sales tax refund or exemption was construed as an incentive scheme for new export-oriented industrial units and eligible modernised units established within the relevant period. A pre-existing unit that had commenced operations in 1958, without showing additional investment or any circumstance bringing it within the scheme, could not qualify merely because it was export oriented. The benefit was confined to units covered by the policy's temporal and substantive conditions, so long-established units outside that class were not entitled to the refund or exemption.

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Issues: Whether a pre-existing industrial unit established long before the Government Order dated 28.8.1993 was entitled to refund or exemption of sales tax meant for export oriented new industrial units.

Analysis: The Government Order was construed as an incentive scheme intended to promote new export oriented industrial units and eligible modernised units within the specified period. The unit in question had commenced operations in 1958 and had not shown any additional investment or other circumstance bringing it within the class of units covered by the policy. Mere status as an export oriented unit was held insufficient to claim the benefit when the scheme was confined to units established or modernised during the relevant period.

Conclusion: The petitioner was not entitled to refund or exemption under the Government Order.

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