In Brief
Prism Cement Limited, a public company, was granted tax exemption under Maharashtra's Package Scheme of Incentives (PSI) 1993 via Eligibility and Entitlement Certificates issued in 1998. After the Central Sales Tax Act was amended in 2002 to require submission of Form 'C' and 'D' for exemptions, the State issued notices demanding payment of previously exempted tax. The Supreme Court held that the 2002 amendment operates prospectively only and cannot retrospectively withdraw rights already accrued under the pre-amendment certificates. The Court dismissed the State's appeal, ruling that substantive rights cannot be unilaterally taken away without notice or formal revocation of the original certificates.
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