Judgment

Srinivasan, J.-The decision in this case depends upon the construc­tion of the relevant provisions of the U.P. Sales Tax Act, 1948 (hereinafter referred to as the ‘Act’) and the Government Notification issued thereunder granting exemption from sales tax of certain goods for specified period. Section 4-A is the Section with which we are concerned and for the purpose of this case the Section as it stood at the relevant time reads as follows:

"4.A. Exemption from sales tax of certain goods for specified period.-(1) Notwithstanding anything contained in Section 3 or 3-A, where the State Government is of the opinion that it is necessary so to do for increasing the production of any goods or for promoting the development of industry in the State generally or in any districts or parts of districts in particular, it may on application or otherwise, by notification, declare that the turnover of sales in respect of such goods by the manufacturer thereof shall, during such period not exceeding seven years from the (date of first sale by such manufacturer if such sale takes place within six months from the date of starting production and in any other case from the date following the exp