JUDGMENT : R. Raghunandan Rao, J. The petitioner was a dealer, registered under the A.P. VAT Act. 2. In the year 2010-2011, one M/s. Abhijeet Ferro-tech Limited established a unit in the Visakhapatnam Special Economic Zone (SEZ). For the purposes of setting up the said plant, an EPC contractor named M/s. Abjhijeet Projects Limited was awarded the contract of setting up the unit. M/s. Abjhijeet Projects Limited in turn sub- contracted the work, on a back to back basis, to the petitioner herein, by way of a letter of intent, dated 04.03.2010. 3. The contention of the petitioner was that, by virtue of Entry59-A in the 1 st schedule to the AP VAT Act, 2005, the petitioner, as a sub- contractor of M/s. Abjhijeet Projects Limited was entitled to an exemption of the turnover relating to the works contract under which the SEZ unit of M/s. Abhijeet Ferro-tech Limited was being established. The further contention of the petitioner was that Entry 59-A, had been interpreted by the erstwhile High Court of Judicature at Hyderabad for the State of Telangana and the State of Andhra Pradesh, in the case of M/s. Larsen and Toubro and Others vs. State of Andhra Pradesh, , [ (2006) 148 STC 616 ] which had held that sub-contractors are also covered under Entry 59-A. 4. As there was some ambiguity about this position of law, upon the subsequent insertion of Section 7-A, the petitioner approached the authority for Advance Ruling. The said authority, by its order, dated 09.06.2009 in A.R.COM/45/2008 had held that even sub- contractors are entitled to the benefit of Entry 59-A of the 1 st schedule to the AP VAT Act. However, the authority for Advance Ruling also held that by virtue of inclusion of Section 7-A, in the AP VAT Act, the benefit available under Entry 59-A is not available any more. Aggrieved by the said order, the petitioner had approached the Sales Tax Appellate Tribunal, by way of T.A.No.66 of 2011. This appeal was dismissed by the Tribunal, by an order, dated 16.05.2011, affirming the view taken by the authority for Advance Ruling. In parallel proceedings, the petitioner was also assessed the tax and the turnover of the petitioner relating to the setting up of the unit in the SEZ area was included and taxed. Apart from this, the authorities also levied a penalty on the petitioner. In parallel proceedings, the petitioner was also assessed the tax and the turnover of the petitioner relating to the setting up of the unit in the SEZ area was included and taxed. Apart from this, the authorities also levied a penalty on the petitioner. Aggrieved by the said order of the Tribunal as well as the orders of the assessment and penalties, the petitioner had approached this Court, by way of various writ petitions. The details of these petitions are as follows: Sl.No. Writ Petition No. Assessment/Penalty Orders challenged in the Writ Petition Appellate Orders challenged in the Writ Petition 01. 16649/2011 A.R.COM/2/2010 Dated 16.03.2011 T.A.No.66 of 2011 dated 16.05.2011 02. 16514/2014 A.A.O.No.37549 Dated 29.04.2014 03. 1415/ 2016 A.O.No.44372 Dated 04.12.2015 04. 29384/2016 A.O.No.26393 Dated 24.06.2016 05. 44149/2016 A.O.No.27737 Dated 08.07.2016 5. Heard Sri A. Sarveswara Rao, learned counsel for the petitioner and the learned Government Pleader for Commercial Taxes. The relevant provisions of law, which require to be considered, are Section 7-A of the AP VAT Act and Entry 59A of Schedule-I of the AP VAT Act. It may also be noticed that Entry 59A was added to the schedule on 01.06.2008 and Section 7A was inserted in the AP VAT Act on 25.09.2008. These provisions read as follows: 7-A Notwithstanding anything contained in this Act, no tax under this Act shall be payable by any dealer in respect of sale of any goods made by such dealer to a registered dealer for the purpose of setting up operation, maintenance, manufacture, trading, production, processing, assembling, repairing, reconditioning, re- engineering, packaging or for use as packing material or packing accessories in an unit located in any Special Economic Zone or for development, operation and maintenance of Special Economic Zone by the developer of the Special Economic Zone, if such registered dealer has been authorized to establish such unit or to develop, operate and maintain such Special Economic Zone by the authority specified by the Central Government in this behalf. 59-A. All goods sold to units, operator, developer, Co- developer and Contractors engaged by them for use in processing area of the respective Special Economic Zones except the goods listed in rule 20(2) (a) of the Andhra Pradesh Value Added Tax Rules, 2005’. 6. Entry 59A exempts all goods sold within the SEZ area by an operator, developer, a co-developer or contractor or by any of the above. 6. Entry 59A exempts all goods sold within the SEZ area by an operator, developer, a co-developer or contractor or by any of the above. The term contractor has now been interpreted to include sub-contractors, by virtue of the Judgment of the erstwhile High Court of Judicature at Hyderabad for the State of Telangana and the State of Andhra Pradesh in M/s. Larsen and Toubro and Others vs. State of Andhra Pradesh , [ (2006) 148 STC 616 ] 7. However, Section 7A, which was introduced subsequently, on 24.09.2008, states that exemption of tax on sale of goods within the Special Economic Zone will be available on sale of any goods to persons who have been authorized to establish unit in the SEZ or authorized to develop operate and maintain a SEZ. The further condition is that only such sales of goods made for the purposes, set out in Section 7A would be eligible for such exemption. 8. The authority for Advance Ruling and the Sales Tax Appellate Tribunal, while interpreting the ambit of Section 7A, took the view that the only provision for exemption, in relation of sale of goods within Special Economic Zones, would be Section 7A and as such, Entry 59A is effectively removed. This view appears to have been taken on the ground that Section 7A starts with a non-obstante clause. 9. The function of a non-obstante clause is to give precedence to a particular provision when there is a conflict between the said provision and any other provision of law, which is sought to be superseded by the non-obstante clause. This would mean that a conflict between the provision of law containing the non-obstante clause and the other provision of law, would have to be found, before the Non obstante clause comes into play. 10. In the present case, entry 59A states that all goods sold by the persons mentioned in entry 59A, would be eligible for exemption. Section 7A also provides for such exemption. However, the said exemption is subjection to certain conditions. 11. When there is a possibility of conflict between two provisions of law, the rule of harmonious construction would have to be applied to see if both provisions of law can operate simultaneously. Applying this principle, we do not find any reason as to why both provisions cannot operate at the same time. 11. When there is a possibility of conflict between two provisions of law, the rule of harmonious construction would have to be applied to see if both provisions of law can operate simultaneously. Applying this principle, we do not find any reason as to why both provisions cannot operate at the same time. At best, Section 7A is a more restrictive provision of law whereas item 59A is a more expansive exemption. It may also be noted Entry 59A was not deleted from the Act, when Section 7A was introduced, and came to be deleted much later. This is also a factor, which has to be taken into account while trying to harmonize both the provisions of law. 12. In the circumstances, we do not find any reason to hold that there is a conflict between Section 7A of AP VAT Act and Entry 59A of the 1 st Schedule to the AP VAT Act. In the absence of a conflict, the non-obstante clause does not come into operation and consequently the petitioner was entitled to the benefit of Entry 59-A of the 1 st schedule which exempts all the sales made by the petitioner, in the course of execution of the works contract, for M/s. Abhijeet Projects Limited. 13. Consequently, all the impugned orders which are set out above are set aside and the Writ Petitions are allowed. It will be open to the Assessing Authority to pass necessary consequential orders.There shall be no order as to costs. As a sequel, pending miscellaneous petitions, if any, shall stand closed.