Purposive reading of incentive scheme denied sales tax exemption beyond the scheme's terminal date despite the longer investment window.

An incentive scheme must be read purposively and harmoniously, so an apparent drafting omission cannot be used to extend sales tax exemption beyond the scheme's terminal date of 31 December 2005. The special 18-month period for large industrial units could not override that cutoff, and the government record and uniform application supported the intended limit. As the petitioner had sought eligibility only up to 31 December 2005 and failed to establish promissory estoppel or discrimination, no exemption was available for later investment. The request for extension of the eligibility certificate had also become infructuous.

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Issues: Whether the petitioner was entitled under the incentive scheme to sales tax exemption on investment made after 31 December 2005 but within 18 months from commencement of commercial production, and whether the request for extension of the eligibility certificate survived.

Analysis: Clause 3.8 of the scheme was construed as a whole. The special period of 18 months for industrial units with project cost exceeding Rs. 10 crores could not be read in isolation so as to nullify the scheme's terminal date of 31 December 2005. The omission of the words indicating that the earlier of the two limits would apply was treated as an inadvertent printing error, supported by the governmental record and by the manner in which the scheme had uniformly been applied to similarly placed units. The petitioner had itself sought eligibility only on investment up to 31 December 2005, and no case of promissory estoppel or discrimination was established.

Conclusion: The petitioner was not entitled to incentive or sales tax exemption on investment made after 31 December 2005, though within 18 months from commercial production. The claim based on investment of Rs. 257.55 crores was rejected, and relief on extension of the eligibility certificate had become infructuous.

Final Conclusion: The writ petition failed on the substantive claim for additional tax incentive and the remaining prayer did not survive, leaving the State's assessment of eligibility under the scheme undisturbed.

Ratio Decidendi: A beneficial incentive scheme must be read purposively and harmoniously, and an apparent drafting omission cannot be construed to extend the benefit beyond the scheme's intended terminal date where the scheme as a whole and its uniform application show the contrary.

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