ORDER K. P. SIVASUBRAMANIAM, J. - The petitioner prays for the issue of a writ of certiorarified mandamus to call for the records of the first respondent dated October 12, 1999 and consequential proceedings of the second respondent dated March 3, 2000 and to quash the same and to permit the petitioner to continue to avail the benefit of the Interest-free Sales Tax deferral scheme. The following facts are sufficient for the disposal of the writ petition considering that the writ petition is to be allowed on the ground of non-compliance of principle of natural justice : The petitioner is an industry, involved in purchase of big stone boulders and disintegrate them into jelly by feeding the boulders into the machines. The finished product "Blue Metal Jelly" is liable to be taxed under item 7-B of Part-B of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959. With a view to encourage the new industry, the State Government was giving incentives for establishment of the new industry. In the year, 1990, deferral of tax for a period of five years was being implemented in respect of new industry and for expansion of the existing industry in backward and most backward areas. There is no dispute over the fact that the petitioner was availing the benefits of interest-free sales tax deferral scheme and had also been issued an "eligibility certificate" after he had entered into an agreement with the Assistant Commissioner of Commercial Taxes. The respondents have now withdrawn the said deferral scheme on the basis of the interpretation of the judgment of this Court in State of Tamil Nadu v. O.P. Aliyar [1992] 87 STC 339. On the basis of the said judgment, the first respondent came to the conclusion that the activity of the petitioner did not amount to any manufacture and therefore, the eligibility certificate was liable to be cancelled. By order dated October 12, 1999/November 3, 1999 the first respondent addressed a letter to the Assistant Commissioner of Commercial Tax, Madurai-1, stating that the eligibility certificate issued in favour of the petitioner was treated as withdrawn. Consequential order was passed by the Assistant Commissioner on March 3, 2000 informing the petitioner that the agreement which was already executed was cancelled in view of the withdrawal of the "eligibility certificate". Aggrieved by the same, the petitioner has come forward with the above writ petition. Consequential order was passed by the Assistant Commissioner on March 3, 2000 informing the petitioner that the agreement which was already executed was cancelled in view of the withdrawal of the "eligibility certificate". Aggrieved by the same, the petitioner has come forward with the above writ petition. I do not propose to go into the merits of the contention as to whether the judgment of this Court in State of Tamil Nadu v. O.P. Aliyar [1992] 87 STC 339 would apply to the petitioner and whether the activity of the petitioner can be termed as amounting to manufacture. Admitted fact discloses that no show-cause notice has been issued before the impugned orders are passed. Learned counsel for the petitioner relies on the judgment of a division Bench of the Punjab & Haryana High Court in R.K. Mittal Woollen Mills v. State of Haryana [2001] 123 STC 248. The division Bench had allowed the writ petition on the ground that no show-cause notice was issued as against the proposed action of withdrawal of the eligibility certificate. In another judgment of the same High Court in Shanti Yarns Pvt. Ltd. v. State of Haryana [2001] 123 STC 261 also the Punjab and Haryana High Court had held that before withdrawal of the eligibility certificate the aggrieved party ought to have been given show cause notice. Learned counsel appearing for the first respondent-corporation, apart from submitting that the classification of the petitioner's unit as manufacturing unit was wrong in terms of the judgment of the Madras High Court, he is not able to show any authority to the effect that no show-cause notice would be necessary. I have also heard learned Government Advocate (Taxes). He would also contend that the activity of the petitioner's establishment amounted only to conversion of the property and the original characteristic of the product was not changed and there was no process of manufacture. Both learned counsel for the respondents are unable to dispute the proposition that before the impugned order was passed, the petitioner will be entitled to a show-cause notice. It is needless to mention that the deferral scheme which was implemented in favour of the petitioner consequent on an agreement executed by the petitioner, results in civil consequences when the said scheme is sought to be withdrawn. Therefore, the necessity to issue show cause notice cannot be dispensed with. It is needless to mention that the deferral scheme which was implemented in favour of the petitioner consequent on an agreement executed by the petitioner, results in civil consequences when the said scheme is sought to be withdrawn. Therefore, the necessity to issue show cause notice cannot be dispensed with. In the result, in the absence of show cause notice, the impugned proceedings are liable to be quashed. The writ petition is allowed with liberty to the respondents to proceed afresh after issuing show cause notice to the petitioner. No costs. Connected miscellaneous petition is closed as unnecessary. Writ petition allowed.