Facts of the Case
The Krishna District Milk Producers Co-operative
Union Limited challenged the common order passed by the Sales Tax Appellate
Tribunal, which had affirmed the orders of the Deputy Commissioner of
Commercial Taxes. The Tribunal held that the assessee was not entitled to
exemption in respect of cattle feed because it was engaged not only in milk and
milk products but also in cattle feed. The Tribunal further held that flavored
milk marketed under the brand name "Milk Break" was
commercially different from fresh or pasteurized milk and, therefore, was not
eligible for exemption under the relevant Government Orders.
The assessee filed Tax Revision Cases before the
High Court under Section 22(1) of the APGST Act challenging these findings.
Issues Involved
- Whether the purchases of milk from unregistered dealers and its
utilization for manufacture and sale of milk by-products were liable to
tax under Section 6A of the APGST Act.
- Whether flavored milk sold under the brand name "Milk
Break" was entitled to exemption applicable to milk products.
- Whether the assessee was entitled to exemption in respect of
procurement and sale of cattle feed under the applicable Government
Orders.
- Whether the assessment orders confirmed by the Sales Tax Appellate
Tribunal were legally sustainable.
Petitioner's Arguments
The petitioner contended that the Government had
subsequently issued a clarification and the Commissioner of Commercial Taxes
had also issued a Circular dated 28.11.2006 making it clear that purchases of
milk from unregistered dealers used in the manufacture of milk by-products were
not liable to tax under Section 6A of the APGST Act.
The petitioner further argued that the Government
had directed withdrawal of the earlier circular authorizing levy of tax and had
also ordered that all demands raised on the basis of such circular should be
treated as waived.
It was also submitted that identical issues had
already been decided by the Composite High Court in favour of similarly placed
milk producers' cooperative societies. Therefore, the present case was fully
covered by those earlier judicial precedents.
Regarding cattle feed, the petitioner relied upon
the Division Bench judgment extending the benefit of G.O.Ms. No.302 dated
20.03.1992 and contended that the exemption was equally applicable to the
petitioner.
Respondent's Arguments
The State contended that the Tribunal had rightly
denied exemption since the petitioner was engaged in cattle feed business in
addition to milk and milk products.
It was also argued before the Tribunal that
flavored milk sold under the brand name "Milk Break" was commercially
distinct from pasteurized milk and therefore not eligible for exemption.
However, before the High Court, the learned
Assistant Government Pleader fairly submitted that the issue relating to cattle
feed stood covered by the earlier Division Bench decision. The State only
requested that if the petitioner had collected tax from customers on cattle
feed sales, the Revenue should be permitted to retain or recover such amount to
avoid unjust enrichment.
Court Order / Findings
The Andhra Pradesh High Court observed that, in
view of the Government clarification dated 17.11.2006 and the Circular dated
28.11.2006 issued by the Commissioner of Commercial Taxes, purchases of milk from
unregistered dealers utilized for manufacture and sale of milk by-products were
not liable to tax under Section 6A of the APGST Act.
The Court noted that the Government had rescinded
the earlier circular authorizing levy of tax and had also directed waiver of
demands raised on that basis.
The Court further relied upon the earlier judgment
of the Composite High Court in the case concerning Guntur District Milk
Producers' Mutually Aided Co-operative Union (Sangam Dairy), wherein similar
assessments had already been set aside.
With regard to cattle feed, the Court held that the
issue was no longer res integra as a Division Bench had already extended the
benefit of G.O.Ms. No.302 dated 20.03.1992 in similar circumstances.
Accordingly, the petitioner was entitled to the same benefit.
The assessment relating to both the sale of cattle
feed and sale of "Milk Break" and its by-products was set aside.
However, the Court clarified that where the
petitioner had already collected tax on sales of cattle feed from customers,
the Revenue would be entitled to retain such amount on the principle of unjust
enrichment.
Accordingly, both Tax Revision Cases were allowed
without any order as to costs.
Important Clarification
- Purchases of milk from unregistered dealers used in manufacture of
milk by-products are not liable to tax under Section 6A of the APGST Act
in view of the Government clarification.
- Earlier circular authorizing levy of tax stood rescinded.
- Tax demands raised pursuant to the rescinded circular were liable
to be waived.
- Exemption relating to cattle feed was available in view of the
binding Division Bench precedent.
- Revenue may retain tax already collected from consumers to prevent
unjust enrichment.
- The Tribunal's assessment on cattle feed and flavored milk products
was set aside.
Sections Involved
- Section 22(1), Andhra Pradesh General Sales Tax Act, 1957
- Section 6A, Andhra Pradesh General Sales Tax Act, 1957
- G.O.Ms. No. 1091 dated 10.06.1957
- G.O.Ms. No. 501 dated 25.05.1987
- G.O.Ms. No. 302 dated 20.03.1992
- Government Memo dated 17.11.2006
- Commissioner of Commercial Taxes Circular dated 28.11.2006
Link to
download the order
https://www.mytaxexpert.co.in/uploads/1784616506_1618compressed.pdf
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