Judgment

BHAGWATI, J. - The appellant owns a jute mill situate at Rajguni, Railway Station Andul, District Howrah in the State of West Bengal and among other jute products, it manufactures jute carpet backing cloth at its jute mill. The appellant exported diverse quantities of jute carpet backing cloth manufactured by it to various countries during the period 13th July 1966 to 30th November. 1966. There was a Tax Credit Certificate Scheme framed by the Central Government under S. 280 ZE read with S. 280 ZC of the Income Tax Act 1961. The Scheme was called the Tax Credit Certificate (Exports) Scheme 1965. The Scheme provided for grant of Tax Credit Certificate in respect of certain categories of goods or merchandise specified in column 2 which were exported to destinations specified in column 4 and the dates of export of which fell after 28th February, 1965, for an amount calculated at the rates specified in column 3 of the Table attached to the Scheme. Jute carpet backing cloth was covered by Item 1 in column 2 of the Table which specified "goods made of jute not otherwise specified". If the Scheme had remained unamended, the appellant would have been entitled to tax credit certific