- (1.) On 12/11/1965, the appellant issued a notification under the provisions of Section 8 (5 of the central Sales Tax Act, 1956, directing that the rate of sales tax on the sale of white printing paper to newspaper concerns in the course of inter-State trade or commerce should be calculated at the rate of 2%. The exemption notification was gazetted on 24/11/1965.
(2.) On 20/3/1967, another notification was issued under the provisions of Section 8 (5 of the central Sales Tax Act, the relevant portions of which read thus: "Cancellation of certain notifications relating to reduction in rate of tax under Section 8 (5 of central Sales Tax Act. (Gop no. 642 Revenue 20th March, 1967 III No. 169 of 1967. In exercise of the powers conferred by Ss. (5 of Section 8 of the central Sales Tax Act, 1956 (Central Act 74 of 1956 the , governor of Madras hereby cancels, with effect on and from the 1/04/1967, the Revenue Department notifications, published in the Fort St. George Gazette, as detailed below:
(3.) On 4/1/1982/16/1/1982, notices of reassessment were issued to the respondents for the period 1975-76 to 1981-82. The notice stated that the exemption notification had been withdrawn on 20/3/1967, and that, therefore, reassessments were required to be made at the un-exempted rate. The notices of reassessment were challenged in a writ petition filed before the High court of Madras. The writ petition was dismissed. The respondents ' filed an appeal before the division bench of the High court. The appeal succeeded, and this appeal by special leave is directed against the division bench's judgment.;