Exemption notification conditions must be satisfied at the time of sale; later certificate cannot erase accrued tax liability.

An exemption under a notification conditioned on the purchaser holding a certificate from the competent authority applies only if that certificate exists at the time of sale. A certificate issued later cannot retrospectively remove a tax liability that had already accrued when the sale took place. The officer's decision to grant a beneficial date from the application was treated as administrative only, because the notification itself gave no basis for earlier effectiveness. The certificate therefore operated only from the date of issue, not from the notification date or the application date, and the issue was answered against the assessee and in favour of the Revenue.

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Issues: Whether the certificate issued under entry 39 of the exemption notification operated from the date of the notification or only from the date on which the certificate was issued to the purchasing dealer.

Analysis: Section 41 empowered the State Government to exempt specified classes of sales from tax subject to conditions imposed by notification. Entry 39 granted exemption only to sales made to a registered dealer who manufactured specified goods and who was certified for that purpose by the Commissioner. The exemption therefore attached only when the purchaser already held the requisite certificate at the time of sale. A later grant of the certificate could not alter a liability to tax that had already accrued on the date of sale. The retrospective date given by the officer from the date of receipt of the application was treated as a beneficial administrative step, but the notification itself contained no basis for treating the certificate as effective from an earlier date.

Conclusion: The certificate operated only from the date of its issue, and not from the date of the notification or the date of application. The question was answered against the assessee and in favour of the Revenue.

Ratio Decidendi: Where an exemption notification conditions tax relief on the purchaser holding a certificate from the competent authority, the exemption applies only if that condition is satisfied at the time of sale, and a certificate obtained later does not retrospectively extinguish the seller's accrued tax liability.

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