M/S. Shakthi Seeds Pvt. Ltd vs Dy. Commnr. (Ct) & Anr

The Supreme Court upheld the dismissal of the appellant's revision petition under Section 22(1) of the Andhra Pradesh General Sales Tax Act, 1957, affirming the Tribunal's decision that both conditions of being 'certified' and 'truthfully labelled' seeds must be satisfied for tax exemption under G.O.Ms. No. 604. The Court found that the appellant failed to provide satisfactory evidence to meet these conditions, thus confirming the tax liability as first purchasers. The ruling clarifies the interpretation of the exemption criteria under the relevant government orders.