Judgment

Mrs. Sujata V. Manohar, J.-At all material times the respondent was an industry engaged in the business of oil extraction and manufacture in the State of Rajasthan.

2. By a notification dated 23rd of May, 1987 issued in the exercise of its powers under Section 4(2) of the Rajasthan Sales Tax Act, 1954, the appellant-State of Rajasthan notified a Sales Tax Incentive Scheme for Industries, 1987 (hereinafter referred to as the “Incentive Scheme”) under which it exempted (inter alia) new industrial units from payment of tax on the sale of goods manufactured by them for sale within the State of Rajasthan in the manner and to the extent and for the period as specified in that notification. The operative period of the scheme under that notification was from 5th of March, 1987 to 31st of March, 1992. It was subsequently extended to 31st March, 1997. The incentive scheme was applicable, inter alia, to new industrial units set up in areas mentioned in Annexure-A to the notifications. Annexure-B sets out a list of industries which were not eligible for the benefit of the said notification. Oil extraction or manufacture was not listed in appendix-B. Hence this industry was eligible for