Sales Tax

Set-off

— Entitlement to — Industrial Policy of the State providing for the benefit of set-off to <169>new industrial units as well as existing units which are not availing of any facility of tax deferment or tax-free purchases or tax-free sales under any notification announced earlier<170> — In such circumstances, an existing unit actually availing of the facility of exemption on the relevant date under notifications issued by the erstwhile larger State from which the State concerned was carved out, held, not entitled to the benefit of the said provision of the Industrial Policy of the State concerned — Literal rule of interpretation applied — In view of the clear provision, contention of the assessee that such an interpretation should be avoided as the same would disentitle almost all the units of the new State to the benefit of the said Industrial Policy, rejected, (2006) 6 SCC 336