Sales tax exemption tied to certificate validity cannot be extended by adding new goods to registration particulars.

A sales tax exemption tied to a newly set up industrial unit, its approval, and the validity period stated in the exemption certificate could not be enlarged merely because M.S. rods were later added to the registration particulars. The amendment did not amount to a fresh approval, fresh registration, or an extension of the certificate's life, and paragraph 2 fixing validity remained unchanged. The exemption therefore continued only up to 5 January 1974, not for a fresh five-year period from 11 September 1970. The claim for exemption beyond the original certificate period failed.

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Issues: Whether the petitioner was entitled to claim sales tax exemption for raw materials used in manufacturing M.S. rods for a fresh five-year period from 11 September 1970, or whether the exemption continued only up to 5 January 1974 in terms of the original certificate.

Analysis: The exemption notification applied only to a newly set up industrial unit approved and registered by the industries department, and the sales tax exemption certificate was to operate within the period stated in the certificate. The mere inclusion of M.S. rods by amendment in the existing registration and exemption particulars did not amount to a fresh approval, a fresh registration, or an extension of the life of the certificate. Since paragraph 2 of the certificate, which fixed its validity, was not amended, the certificate continued to expire on 5 January 1974. The petitioner therefore could not claim a renewed five-year exemption from the date M.S. rods went into production.

Conclusion: The claim for a fresh exemption period from 11 September 1970 failed, and the petitioner was not entitled to exemption beyond 5 January 1974.

Final Conclusion: The writ petition was dismissed because the impugned orders correctly held that the exemption under the notification did not extend beyond the original validity period of the certificate.

Ratio Decidendi: A tax exemption granted under a notification tied to approval, registration, and a fixed certificate period cannot be enlarged by mere amendment of the goods covered unless the certificate itself is validly extended or reissued for the fresh unit or activity.

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