State Of U.P. And Ors vs Deepak Fertilizers & Petrochemical ...

The Supreme Court upheld the High Court's ruling that the notification dated 10th April 1995, which withdrew the tax exemption for NPK 23:23:0 fertilizers, could not be applied retrospectively. The Court emphasized that such notifications must be prospective in nature, referencing the U.P. Trade Tax Act, 1948, particularly Section 25. The Court affirmed the High Court's decision to direct the State to include NPK 23:23:0 in the exemption list, thereby ensuring fair treatment under tax law.