STATE OF MADHYA PRADESH AND ANR. vs G.S. DALL AND FLOUR MILLS

The Supreme Court held that the notification dated 23.10.1981 issued under Section 12 of the Madhya Pradesh General Sales Tax Act, 1958, exempting certain dealers from sales tax, was not intended to cover 'traditional industries' as defined by subsequent rules and instructions. The Court affirmed the High Court's view that executive instructions could not override statutory notifications, emphasizing that the exemption was limited to new industrial units. The Court ultimately upheld the Division Bench's decision, rejecting the Full Bench's interpretation that expanded the scope of the exemption.