Judgment

B.P. JEEVAN REDDY, J.

(1) LEAVE granted.

(2) THE appeals are preferred against a common judgment of the orissa High court in five writ petitions. All the five writ petitions were filed by the respondent herein, Jagannath Cotton Company, wherein the question is whether the respondent is entitled to the benefit of exemption from sales tax under the Industrial Policy Resolutions of 1986 as well as of 1989. It also involves the question whether the process undertaken by the respondent, applying which he obtains cotton from waste cotton, can be called manufacturing activity.

(3) WITH a view to encourage the industrialisation of the State, the government of orissa published the Industrial Policy Resolution (dated 13/5/1986 in the Gazette of 11/6/1986. It provided several incentives to those establishing new industries in the State and also those who expanded their existing capacities. Inter alia, it provided for certain concessions in the matter of sales tax. In the case of village, cottage and small-scale industries, exemption from tax was provided on the purchase of raw material as well as the sale of finished product whereas in the case of n