Fixed-term sales tax exemption schemes cannot be extended without an enabling provision, and courts cannot rewrite the benefit terms.

An industrial incentive scheme granting sales tax exemption for a fixed period from the date of production could not be extended in the absence of an enabling provision. The Court held that the certificates operated strictly according to their terms, and the petitioner's claim of delayed issuance was unsupported because the initial application had been rejected for non-compliance and the benefit was availed only after a substantial gap. It further held that writ jurisdiction could not be used to direct the authorities to frame or rewrite the scheme. The challenge to the rejection of extension therefore failed.

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Issues: Whether the petitioner was entitled to extension of the period of exemption from payment of sales tax under the industrial incentive scheme.

Analysis: The industrial unit had been granted eligibility and exemption certificates making the benefit available from the date of production for a fixed period or until the monetary ceiling was exhausted. The Court found that the scheme did not contain any provision enabling extension of the eligibility period for any reason. The plea that the certificates were issued late was not supported by the record, as the initial application had been rejected for non-compliance of formalities and the petitioner had started availing of the benefit only after a substantial gap. The Court also held that it could not direct the authorities to frame or rewrite the rules in exercise of writ jurisdiction.

Conclusion: The petitioner was not entitled to any extension of the exemption period, and the challenge to the rejection order failed.

Final Conclusion: The industrial incentive scheme was held to operate strictly according to its terms, and no extension could be granted in the absence of an enabling provision.

Ratio Decidendi: Where a fiscal exemption scheme fixes the commencement and duration of the benefit and contains no provision for extension, the Court cannot enlarge the benefit beyond the statutory terms.

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