IN THE HIGH COURT AT CALCUTTA CONSTITUTIONAL WRIT JURISDICTION ORIGINAL SIDE Present:

The Hon’ble Justice Kausik Chanda R.V.W.O No.5 of 2024 with I.A. No. G.A. 2 of 2024 SALES TAX OFFICER, BARASAT CHARGE AND OTHERS -VERSUS-

SANJAY SUR AND ANOTHER For the petitioners : Mr. Md. T. M. Siddiqui, Sr. Adv., Mr. Tanoy Chakraborty, Adv., Mr. Saptak Sanyal, Adv.

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For the respondents : Mr. Prabhat Kr. Singh, Adv., Mr. Prashant Kr. Singh, Adv.

Hearing concluded on : 17.12.2025 Judgment on : 02.02.2026 Kausik Chanda, J.:-

By filing this review application, the revenue seeks review of an order dated April 10, 2023 passed by a learned Single Judge of this Court. Before delving into the merits of the review application, it is necessary to outline the factual context in which the order dated April

10, 2023 was passed.

2. The writ petitioners are engaged in the cotton trade and are predominantly exporters. For the 3rd and 4th quarters of the assessment year 2010–11, the writ petitioners applied for 73 declarations in Form “H” before the Sales Tax Officer, Barasat Charge, in order to obtain certain export-related benefits.

3. By an order dated March 3, 2013, the Sales Tax Officer rejected the writ petitione