JUDGMENT :

Anil R. Dave, J.

1. Being aggrieved by the common judgment delivered by the Gauhati High Court on 14th November, 2006, the appellants have approached this Court by way of these appeals.

2. The facts giving rise to the present litigation, in a nutshell, are as under:

As the legal issues involved in all of the aforesaid appeals are same, for the purpose of convenience, we have taken facts from Civil Appeal No.2806 of 2009.

3. The appellant is a private limited company engaged in the business of blending and packing of tea. After some modernisation, it commenced its production in April, 1988. The case of the appellant-Company was with regard to availing sales tax concession declared by the respondent-State. Before going through the relevant provisions, we may record the fact that the respondent-State had notified its Industrial Policy in 1982, which had thereafter been revised in 1986. The said Policy had been framed so as to increase economic and industrial growth in the State.

4. In pursuance of the aforestated Policy, the respondent-State enacted Assam Industries (Sales Tax Concession) Act, 1987 (hereinafter referred to as “the Act”). By virtue of the provisions of the Act, ce