Judgment

( 1 ) THIS batch of appeals has been preferred by small-scale industrial units which carry on the business of manufacturing edible oils in the State of jammu and Kashmir. The manufacture of edible oils was exempted from payment of sales tax under Exemption Notification No. SRO-93 dated 27-3-1991 which granted exemption to small-scale industrial units for the period 1-7-1990 onwards from payment of general sales tax under the Jammu and Kashmir General Sales Tax Act, 1962, provided that the goods manufactured were not of the kind specified in Annexure a to the notification. Annexure a consisted of two parts. The first contained details of the period for which exemption was to be granted and the extent of exemption. Thus 100% exemption was granted up to 31-3-1995, 50% till 31-3-1998 and 25% till 31-3-2000. The second part specified the excluded industries (which is referred to hereinafter as "the Negative List") which did not include edible oils. Consequently, the appellants before us were entitled to exemption under Notification No. SRO-93 of 1991.

( 2 ) ON 19-1-1995 a government order was issued, being GO No. 10 of 1995, which enunciated the States policy in respect of new u