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    <title>2019 (11) TMI 423 - MADRAS HIGH COURT</title>
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    <description>Section 12C of the Tamil Nadu General Sales Tax Act was applied to pending assessments already initiated before 01.04.2006 where the statutory conditions were met, so pre-assessment proceedings did not by themselves exclude the scheme. Denial of that benefit was justified only for the first-year assessment because the rule expressly excluded such cases, while unproved allegations of suppression could not disqualify the assessee without clear establishment of suppression and due hearing. An exemption for cotton yarn sales to registered exporters also could not be withdrawn for the period in question on the basis of a later departmental clarification, since the earlier consistent assessment practice and non-disclosure of the clarification supported the assessee&#039;s claim.</description>
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