Exemption period under approval-linked notification starts only on clear Central Government approval, not on a letter of intent.

Where an exemption notification ties the benefit to approval by the Central Government, the five-year period begins only on clear and unconditional approval. A conditional letter of intent was not treated as the reckonable approval, while the Green Card constituted the operative approval for exemption purposes. Commencement of production was held irrelevant because the notification linked eligibility to approval, not to actual production. The reckonable date was therefore 27-10-1994, and the assessee could claim the exemption only from that date.

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Issues: Whether, for the purpose of exemption under SRO 1727/1993, the five-year period was to commence from the date of the letter of permission dated 16-12-1993 or from the date of the Green Card dated 27-10-1994.

Analysis: The exemption notification granted relief for five years from the date of approval by the Central Government. The letter dated 16-12-1993 was treated as a conditional permission or letter of intent, not as an unambiguous approval. The Green Card dated 27-10-1994 was the clear approval by the Central Government enabling the assessee to claim the exemption. The commencement of production was held to be irrelevant for determining the reckonable date, because the notification tied the benefit to approval and not to actual production.

Conclusion: The reckonable date for exemption was 27-10-1994, and the assessee could avail the exemption only after that date.

Ratio Decidendi: Where an exemption notification links the benefit to approval by the Central Government, the exemption period begins only on clear and unconditional approval, not on a mere letter of intent or on commencement of production.

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