Statutory rebate depends on account production and scrutiny; provisional returns alone do not secure the deduction.

A statutory rebate under rule 18 of the Madras General Sales Tax Rules is available only on compliance with the prescribed conditions, including production of accounts for verification at final assessment. Monthly returns accepted provisionally do not extinguish the assessing authority's power under rule 13 to scrutinise the accounts and determine whether the rebate claim is proved. The filing of A-3 returns therefore does not by itself entitle the assessee to rebate where the supporting accounts are not produced. The discussion distinguishes prior authority where rebate was denied for incorrect or suppressed accounts after the statutory conditions had otherwise been met.

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Issues: Whether a registered manufacturer of groundnut oil was entitled to rebate under rule 18 of the Madras General Sales Tax (Turnover and Assessment) Rules for the relevant period despite non-production of accounts, when monthly returns had been filed and accepted provisionally.

Analysis: Rule 18 conferred a deduction or rebate only subject to the conditions prescribed by that rule, and rule 18(3) required monthly statements to reach the registering authority so that the assessing authority could determine the deduction. Rule 13 preserved the power of final assessment after scrutiny of the accounts and satisfaction that the returns were correct and complete. Filing monthly A-3 returns did not absolve the assessee from producing the accounts, because provisional acceptance of returns was only a convenient method of payment and did not displace the statutory power of scrutiny at final assessment. The earlier decision relied on by the assessee was distinguishable, as it dealt with denial of rebate on the ground of incorrect accounts or suppression after the statutory conditions had otherwise been satisfied, whereas the present case turned on failure to produce accounts needed to verify the claim.

Conclusion: The assessee was not entitled to rebate for the period for which the accounts were not produced, and the challenge to the assessment failed.

Ratio Decidendi: A statutory rebate subject to prescribed conditions cannot be claimed as of right merely because provisional monthly returns were accepted; the assessing authority may require production and scrutiny of accounts at final assessment to verify compliance with those conditions.

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