Notification interpretation confirms concessional diesel tax benefit for eligible industrial units without an exclusion clause.

The notification dated 10.08.2017 was interpreted as applying to all industrial units engaged in the manufacture of taxable goods, with no exclusion for sugar industries or for units also benefiting under another notification. On that reading, the respondent fell within the notification's ambit and was entitled to purchase diesel at the concessional tax rate. The Supreme Court found no error of law in the High Court's interpretation and rejected the Revenue's challenge.

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Issues: Whether the respondent was entitled to the benefit of the notification dated 10.08.2017 for purchase of diesel at the concessional rate of tax, despite also availing benefit under another notification.

Analysis: The High Court had held that the notification dated 10.08.2017 applied to all industrial units engaged in manufacture of taxable goods and contained no clause excluding sugar industries or units already receiving benefit under the notification dated 07.12.2019. The Court found no error of law in that interpretation and agreed that the respondent fell within the ambit of the notification.

Conclusion: The respondent was entitled to the benefit of the notification dated 10.08.2017 and the Revenue's challenge failed.

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