In Brief
Dugar Tea Industries, a company engaged in blending and packing tea, sought sales tax exemption under Assam's industrial policy and the Assam Industries (Sales Tax Concession) Act, 1987. The company relied on an eligibility certificate issued in 1988. The State denied exemption, arguing that tea is statutorily excluded from the definition of 'raw material' and that blending/packing does not constitute manufacturing. The Supreme Court upheld the denial, holding that tea is expressly excluded from raw materials under the Rules, that a mandatory Certificate of Authorisation was never issued, and that promissory estoppel cannot override statutory law. The appeals were dismissed."/> </invoke>
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