Form III-C(1) certificate cannot cover multiple transactions, but exemption claim must still be examined transaction-wise.

Rule 12-B under the U.P. Sales Tax Act required the form III-C(1) certificate to be linked to a single bill, cash memo, or sale or purchase account, so one certificate could not validly cover multiple transactions. The assessee's certificate was defective to that extent and could not support exemption for the whole aggregate amount. However, the defect did not justify rejection of the exemption claim in toto, because the assessee was entitled to choose the transaction to which the certificate would be applied, and the claim had to be examined transaction-wise on that basis.

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Issues: Whether a single certificate in form III-C(1) could validly cover more than one transaction, and whether the assessee's claim to exemption under section 3-D(2) could be rejected in entirety on that basis.

Analysis: Rule 12-B, inserted under the U.P. Sales Tax Act, governed exemption claims under section 3-D. Under sub-rule (7)(a), the certificate in form III-C(1) was to be issued by the dealer making the first purchase, and sub-rule (9) expressly provided that no single certificate could cover more than one bill, cash memo, or account of sale or purchase. The certificate filed by the assessee covered more than one transaction, so it could not support exemption for the entire aggregate amount. At the same time, the defective certificate could not be rejected in toto, because the assessee was entitled to select the transaction to which the certificate would be applied.

Conclusion: A single certificate in form III-C(1) could not cover multiple transactions, but the assessee's exemption claim could not be wholly denied and had to be examined transaction-wise on the assessee's choice.

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