JUDGMENT

S.P. Bharucha, J.-The appellant was issued an eligibility certificate under the provisions of an exemption notification dated 9th February, 1977 issued in exercise of the power conferred by Section 10 of the Madhya Pradesh Sthaniya Kshetra Me Mal Ke Pravesh Par Kar Adhiniyam, 1976. The said certificate granted to the appellant an exemption for raw materials required by it in the process of manufacture. In the words of the judgment of the High Court, "The raw material, as per the certificate, included for exemption was Limestone, Laterite & Iron Ore, Gypsum, Pozzolanic Materials such as Coal Ash, Cal Slinder, Brick Bats & Calcine Clay, etc., all types of coal, Lubricants and gunny bags. Later, the certificate was amended to include consumable goods including spares and ancillaries......". (Emphasis supplied). The period of the exemption under the said certificate commenced on 21st October, 1982 and concluded on 20th October, 1987.

2. On 25th March, 1991, long after the period specified in the said certificate had expired, the appellant was issued a notice by the District Industries Centre of the first respondent. The notice was on the subject of "Review of the Entry Tax Exemp