https://www.taxtmi.com/caselaws?id=156094 The 1987 exemption notification on purchase tax for groundnuts and groundnut seeds was construed harmoniously with the earlier 1983 exemption for sale turnover of tiny sector industrial units. The Court held that the later notification could not be applied mechanically to require proof of tax payment on sales of non-refined groundnut oil where such units were already exempt from sale tax and could not produce that proof. A condition that was impossible of compliance for the intended class would defeat the exemption scheme and frustrate its object of encouraging tiny industrial units. The Commissioner's contrary circular was therefore not binding on assessing authorities, and the exemption remained available to the petitioners. en-us Wed, 06 Sep 1989 00:00:00 +0530 Fri, 13 Sep 2013 15:24:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=156094 The 1987 exemption notification on purchase tax for groundnuts and groundnut seeds was construed harmoniously with the earlier 1983 exemption for sale turnover of tiny sector industrial units. The Court held that the later notification could not be applied mechanically to require proof of tax payment on sales of non-refined groundnut oil where such units were already exempt from sale tax and could not produce that proof. A condition that was impossible of compliance for the intended class would defeat the exemption scheme and frustrate its object of encouraging tiny industrial units. The Commissioner's contrary circular was therefore not binding on assessing authorities, and the exemption remained available to the petitioners. Case-Laws VAT and Sales Tax Wed, 06 Sep 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=156094