STATE OF ORISSA AND ORS. vs M/S VIJAY LAXMI OIL INDUSTRIES

The Supreme Court upheld the High Court's decision to grant sales tax exemption to M/s. Vijay Laxmi Oil Industries under the Industrial Policy Resolution (IPR) 1989, despite the appellant's claim that the respondent was ineligible under IPR 1986. The Court clarified that industries established under the framework of previous IPRs could avail benefits under subsequent IPRs, provided they met the eligibility criteria. The Court held that the respondent's investment and commencement of production were valid under IPR 1989, thus entitling them to the exemption sought.