JUDGMENT

V.S. SIRPUKAR, J. —

1.The Judgment of the High Court denying the exemption from payment of Sales Tax is under challenge in this appeal at the instance of the Appellant Pondicherry State Cooperative Consumer Federation Ltd. (for short “the Assessee”). Such exemption was granted by the Sales Tax Appellate Tribunal at Pondicherry by allowing an appeal filed by the Assessee. Prior to that the Assessee was assessed by the Assessing Authority and on an appeal by the Assessee the taxable liability was brought down to Rs.14,26,729.86 by the Appellate Commissioner. An appeal was, thereafter, filed before the Tribunal which allowed the appeal holding that the Assessee was covered by the G.O.Ms.No.15/74 dated 25.6.1974 and was as such exempted from paying the Sales Tax.

2.The Assessee is a Small Scale Industry certified as such by Director of Industries, Government of Pondicherry by G.O. No.35/IND/88-89/A-5/A-9 dated 19.5.1989. The said certificate specifically provided that the Unit of the Assessee was exempted from payment of Sales Tax for five years vide G.O.Ms.No.15/74/FIN (CT) dated 25.6.1974. It is obvious that thereafter this tax holiday was extended from time to time. The Asses