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SC upheld tax exemption benefits granted to respondent under Package Scheme of Incentives 1993, ruling that amended Section 8(5) of CST Act requiring Form 'C' and 'D' for interstate sales applies prospectively from 11.05.2002. Respondent's eligibility certificate dated 20.02.1998 and entitlement certificate dated 24.03.1998 granted absolute exemption up to 2012 or Rs.273.54 crore without Form 'C'/'D' requirements. State's revision notices demanding exempted tax for non-submission of forms were invalidated as substantive rights had accrued prior to amendment. Court emphasized retrospective application would impair vested rights, dismissing appeal and confirming exemptions without form submission requirements for pre-amendment period.
SC upheld tax exemption benefits granted to respondent under Package Scheme of Incentives 1993, ruling that amended Section 8(5) of CST Act requiring Form 'C' and 'D' for interstate sales applies prospectively from 11.05.2002. Respondent's eligibility certificate dated 20.02.1998 and entitlement certificate dated 24.03.1998 granted absolute exemption up to 2012 or Rs.273.54 crore without Form 'C'/'D' requirements. State's revision notices demanding exempted tax for non-submission of forms were invalidated as substantive rights had accrued prior to amendment. Court emphasized retrospective application would impair vested rights, dismissing appeal and confirming exemptions without form submission requirements for pre-amendment period.
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