Sales tax exemption can be limited to the remaining notified period once lease registration satisfies statutory eligibility.

Section 4-A of the U.P. Sales Tax Act permits exemption wholly or partly, so relief may be confined to the balance of the notified period once statutory conditions are met. Where the lease-based eligibility requirement under the Explanation is satisfied only on registration of the lease deed, the exemption becomes operative from that date, not before. The Court therefore treated the respondent as eligible only from 27 March 1990 for the remaining notified period and declined to require a remand because the material facts were clear.

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Issues: Whether the respondent was entitled to sales tax exemption under section 4-A of the U.P. Sales Tax Act, 1948 only from the date on which the lease deed was registered, and whether the exemption could be restricted to the remaining part of the notified period.

Analysis: Section 4-A(1) contemplates grant of exemption wholly or partly, which permits exemption for only part of the notified period once the statutory conditions are satisfied. Under clause 1(c) of the Explanation, where land or building is taken on lease for not less than seven years, the requirement is satisfied from the date on which registration of the lease deed is completed. Section 4-A(5)(b) further provides that if the application is made later than the specified date, the facility operates only for the part of the notified period computed from the date of the application till the end of that period. The respondent satisfied the relevant condition on 27 March 1990, and the Court found no need to remit the matter because the facts were clear and relief could be moulded.

Conclusion: The respondent was entitled to exemption only from 27 March 1990 for the remaining period, namely 3 years 1 month and 4 days, and not for the entire earlier period claimed.

Ratio Decidendi: Where the statute permits exemption wholly or partly, and the substantive eligibility condition is fulfilled only later, exemption may be granted prospectively from the date of compliance for the balance of the notified period.

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