Abatement of SICA proceedings ends interim rehabilitation benefits, leaving no enforceable right to continue CST exemption or defeat tax demands.

Once SICA proceedings abate on repeal, interim protections and ancillary benefits under a sanctioned rehabilitation scheme do not survive unless independently preserved by law. The Court held that the petitioner could not enforce continuation of CST exemption after the Sick Industrial Companies (Special Provisions) Repeal Act, 2003 came into force, and there was no remaining enforceable right based on the extinguished BIFR proceedings. It also noted that the earlier order in the petitioner's favour had already been set aside in appellate proceedings. On that basis, the writ court found no ground to quash the tax demands or grant relief.

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Issues: Whether the petitioner was entitled to enforcement of the sanctioned rehabilitation scheme and continuation of CST exemption despite the repeal of SICA and abatement of pending proceedings, and whether the tax demands could be quashed.

Analysis: The sanctioned scheme and the interim protections granted in the BIFR proceedings could not survive once the Sick Industrial Companies (Special Provisions) Repeal Act, 2003 came into force and pending proceedings abated by statutory operation. The Court also noted that the order earlier passed in the petitioner's favour had already been set aside in appellate proceedings and that no enforceable right remained to insist on continuance of the exemption. In these circumstances, the writ court found no basis to interfere with the tax demands or to grant relief on the strength of the extinguished SICA proceedings.

Conclusion: The issue was decided against the petitioner and in favour of the Revenue.

Final Conclusion: The writ petition failed, and the petitioner was held not entitled to any relief in respect of the claimed CST exemption or the impugned demands.

Ratio Decidendi: Once SICA proceedings abate on repeal, interim and ancillary benefits flowing from those proceedings do not survive unless independently preserved by law.

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