Ambiguity in sales tax deferral computation justified fresh administrative determination instead of final writ adjudication.

Where computation of Base Production Volume and Base Sales Volume under a sales tax deferral scheme depends on unresolved ambiguity in the scheme and eligibility certificate, the matter may not be suitable for final determination in writ jurisdiction. The text notes uncertainty over whether Base Sales Volume covers only taxable local sales or also branch transfers, interstate sales, and exports, creating a factual and interpretive dispute on the deferral benefit. The appropriate course was fresh consideration by the competent departmental authorities, after hearing the assessee and without being influenced by earlier observations. The merits of the computation issue were left open for administrative redetermination.

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Issues: Whether the dispute regarding computation of Base Production Volume and Base Sales Volume under the sales tax deferral scheme should be decided in writ proceedings or left to a joint committee of the concerned departments for fresh determination.

Analysis: The eligibility certificate and the scheme conditions did not clearly resolve whether Base Sales Volume included only taxable local sales or also branch transfers, interstate sales, and exports. The resulting ambiguity had led to a dispute between the assessee and the Revenue on the manner of computing the deferral benefit. Since that factual exercise required clarification of the scheme terms and the proper computation of turnover, the matter was not suitable for final determination in writ jurisdiction under Article 226. The appropriate course was to have the concerned authorities reconsider the issue jointly after hearing the assessee and without being influenced by earlier observations.

Conclusion: The dispute over Base Production Volume and Base Sales Volume was directed to be reconsidered afresh by a joint committee of senior officials of SIPCOT and the Commercial Taxes Department.

Final Conclusion: The writ appeals were disposed of by remitting the matter for fresh administrative decision on the core eligibility and computation question, leaving the merits open.

Ratio Decidendi: Where the computation of eligibility under a deferral scheme turns on unresolved factual and interpretive ambiguity in the administrative record, the High Court may decline to finally decide the controversy in writ jurisdiction and direct fresh determination by the competent authorities after hearing the affected party.

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