Mandatory compliance with rebate conditions bars sales tax relief where prescribed certificate is filed late.

A sales tax rebate notification requiring a prescribed certificate within a stipulated time was treated as imposing a mandatory condition for availing the concession. The dealer's failure to furnish the certificate within time defeated the rebate claim, and the benefit could not be retained on a directory reading of the requirement. The Supreme Court followed its earlier ruling on the same point and confirmed that conditions attached to a tax concession must be strictly complied with when compliance is required for entitlement to the benefit.

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Issues: Whether the time-limit condition in the sales tax notification for furnishing the prescribed certificate was mandatory or merely directory, so as to entitle the dealer to the rebate despite non-compliance.

Analysis: The notification granted a rebate subject to specified conditions, including furnishing a certificate in the prescribed form within the stipulated time. The dealer failed to comply with that requirement, and the assessing and appellate authorities rejected the claim. The High Court treated the condition as directory and relied on surrounding material to uphold the claim. The Supreme Court followed its earlier decision on the same point and held that a condition attached to the grant of concession must be treated as mandatory when compliance is required for availing the benefit.

Conclusion: The condition was mandatory, and the dealer was not entitled to the rebate without compliance.

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