Industrial policy exemption ceiling and late Form-IV filing could not justify concessional purchase tax treatment.

The industrial policy exemption operated subject to a fixed ceiling, and where the assessee had already exhausted most of the available benefit for the year, only the remaining balance could be applied. The claim to treat the entire purchase value of raw materials at the concessional 4% rate was unsupported on the record, so the higher 16% levy on the remaining taxable amount was sustained. Form-IV could not be introduced at the revision stage to change the tax position, and the earlier clarification that policy benefits operate over and above the sales tax enactment did not override the exhausted ceiling or the manner in which the claim was made.

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Issues: Whether the assessee was entitled to have the balance exemption under the industrial policy applied against the tax on purchase of raw materials at 4% instead of 16%, and whether it could be permitted at the revision stage to produce Form-IV for that purpose.

Analysis: The exemption under the industrial policy was subject to a fixed ceiling and the assessee had already exhausted substantial benefits for the relevant assessment year, leaving only a limited balance available. The assessee had claimed the purchase exemption on the basis of Form I-D (92) for the entire purchase value, but the materials on record did not support treating the whole amount as eligible for the lower concessional rate. Since Form-IV had not been furnished at the relevant stage, the assessee could not be allowed to introduce it later to alter the tax position. The earlier clarification that industrial policy benefits operate over and above the sales tax enactment did not assist the assessee in the face of the exhausted ceiling and the manner in which the claim had been made.

Conclusion: The assessee was not entitled to substitution of the 4% rate for the balance purchase value, and the levy at 16% on the remaining taxable amount was upheld.

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