In Brief
Bajaj Hindustan Ltd, a sugar mill, stored sugar in an unapproved rented godown outside its factory premises and paid the required tax upon removal. The tax authorities later granted ex-post facto approval but still imposed a penalty, arguing prior approval was necessary. The Supreme Court held that 'approval' in the statutory proviso includes subsequent approval unless the statute explicitly requires 'prior' approval. Since the word 'prior' was absent from Section 3-A and tax was fully paid, ex-post facto approval was sufficient compliance. The Court allowed the appeal and set aside the penalty.
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