Mandatory statutory declaration for tax exemption cannot be replaced by other evidence under the prescribed proof regime.

Section 3-D(7)(a) treated the prescribed declaration or certificate as the statutory mode of proof for claiming purchase or sales tax exemption, and Rule 12-B supplied the mandatory form for that proof. The provision created a deeming fiction and allowed rebuttal only through compliance with the prescribed procedure, so alternative evidence could not replace the statutory declaration. The earlier contrary view was rejected, and strict adherence to the formal requirement was affirmed as the condition for obtaining the tax benefit.

---

---

Issues: Whether the requirement of furnishing the prescribed declaration or certificate under section 3-D(7)(a) for claiming exemption from purchase or sales tax was mandatory, and whether the assessee could adduce other evidence in lieu of the prescribed form.

Analysis: Section 3-D(7)(a) created a deeming fiction and permitted rebuttal of the statutory presumption only by proving the transaction in the manner prescribed. Rule 12-B prescribed the relevant declaration forms as the statutory mode of proof. The provision was treated as one conferring a tax benefit subject to strict compliance with the prescribed formalities, and the inability to produce the form did not justify recourse to other evidence. The earlier contrary view was rejected, and the requirement was held to be mandatory rather than directory.

Conclusion: The assessee was not entitled to exemption without furnishing the prescribed declaration or certificate, and other evidence could not substitute for the statutory form.

Final Conclusion: The statutory mechanism for claiming the exemption had to be strictly complied with, and the assessment authority's refusal of exemption was upheld.

Ratio Decidendi: Where a taxing provision grants exemption only upon compliance with a prescribed statutory mode of proof, that mode is mandatory and cannot be replaced by alternative evidence.

---