Tax on paddy and rice notifications prevented further levy on inter-State rice sales under binding precedent.

Where paddy had already suffered tax at the general rate, the governing notification scheme was read as preventing any further tax on inter-State sale of rice manufactured from that paddy. The Rajasthan HC relied on its earlier binding decisions treating the notifications as a coordinated scheme and rejecting the view that the State could issue a redundant notification. On that footing, the assessee was entitled to the benefit recognised in the prior rulings, and the pending challenge before the Supreme Court did not justify postponing disposal. The petition was dismissed because the claim remained covered by existing precedent.

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Issues: (i) Whether the assessee was entitled to exemption from tax on inter-State sale of rice where full tax had already been paid on paddy from which the rice was manufactured.

Issue (i): Whether the assessee was entitled to exemption from tax on inter-State sale of rice where full tax had already been paid on paddy from which the rice was manufactured.

Analysis: The dispute turned on the scheme of the State tax notifications and the interaction between the tax paid on paddy and the liability, if any, on rice sold in the course of inter-State trade. The Court relied on its earlier decisions holding that where paddy had suffered tax at the general rate and not at the concessional rate, the benefit of the relevant notification operated so that no further tax was payable on the rice. The earlier reasoning treated the notifications as part of a coordinated scheme and held that the State could not be presumed to have issued a redundant notification. The pending challenge before the Supreme Court did not justify deferring disposal of the matter.

Conclusion: The assessee was not denied the benefit of the earlier binding rulings, and the petition was dismissed.

Final Conclusion: The petition failed because the issue stood covered by prior binding decisions of the same Court, and the assessee's claim to relief did not survive in this proceeding.

Ratio Decidendi: Where paddy has suffered tax at the general rate and the governing notification scheme supports adjustment or exemption, no further tax can be levied on inter-State sale of rice merely because rice is manufactured from that paddy.

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