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    <title>2025 (2) TMI 1014 - ANDHRA PRADESH HIGH COURT</title>
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    <description>Section 7-A of the Andhra Pradesh Value Added Tax Act, 2005 did not override Entry 59-A of Schedule I where both provisions could operate concurrently. Entry 59-A granted exemption for goods sold to units, operators, developers, co-developers and contractors engaged in the processing area of a Special Economic Zone, while Section 7-A imposed a narrower conditional exemption. The court applied the principle that a non-obstante clause prevails only in the presence of a real and irreconcilable conflict, and found no such inconsistency. The continued existence of Entry 59-A also supported harmonisation rather than implied repeal. The assessee was therefore entitled to the exemption for sales made in execution of the works contract, and the assessment, appellate and penalty orders were liable to be set aside.</description>
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      <description>Section 7-A of the Andhra Pradesh Value Added Tax Act, 2005 did not override Entry 59-A of Schedule I where both provisions could operate concurrently. Entry 59-A granted exemption for goods sold to units, operators, developers, co-developers and contractors engaged in the processing area of a Special Economic Zone, while Section 7-A imposed a narrower conditional exemption. The court applied the principle that a non-obstante clause prevails only in the presence of a real and irreconcilable conflict, and found no such inconsistency. The continued existence of Entry 59-A also supported harmonisation rather than implied repeal. The assessee was therefore entitled to the exemption for sales made in execution of the works contract, and the assessment, appellate and penalty orders were liable to be set aside.</description>
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