THE STATE OF KERALA STATE OF KERALA JOINT COMMISSIONER (LAW) vs M/S AKAY FLAVOURS AND AROMATICS LTD. — C.A. No. 7330/2009

Summary The Supreme Court held that the exemption period for sales tax on raw materials and machinery for export-oriented units begins from the date of "approval" by the Central Government, which it determined to be October 27, 1994 (the Green Card date), not December 16, 1993 (the letter of intent) or the production commencement date of October 1, 1995. The court interpreted the December 1993 letter as mere conditional permission rather than unambiguous approval, and rejected the assessee's argument that the exemption should commence from production start date, reasoning that unit holders should not be rewarded for delayed implementation. The appeals were partly allowed accordingly. This case analysis is maintained by casestatus.in based on publicly available court records.