Exemption scheme or policy cannot be applied retrospectively....

Exemption scheme or policy cannot be applied retrospectively. Petitioner purchased a hybrid vehicle and paid applicable tax before the exemption policy was introduced. Although vehicle was registered after policy date, tax payment occurred earlier. Supreme Court precedent mandates strict interpretation of exemption notification eligibility criteria. Petitioner ineligible for tax refund under the exemption policy since tax was paid prior to policy introduction. High Court dismissed petition seeking refund direction as no case was made out.