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Issues: Whether exemption under the sales tax rules could be claimed without filing form I declarations and proved by some other evidence.
Analysis: The claim for exemption was rejected because form I declarations were not filed before the assessing authority or the Tribunal. Rule 6-A was treated as requiring filing of form I declarations for claiming exemption, and the earlier decision relied on by the assessee was distinguished as dealing only with acceptance of copies of form I in place of originals as substantial compliance. The Court held that allowing exemption to be established by other evidence would amount to reading into the rule a mode of proof not provided by it.
Conclusion: The requirement to file form I declarations was upheld, and the assessee could not substantiate the exemption claim by any alternative mode of proof; the decision was against the assessee.
Ratio Decidendi: Where a tax exemption rule mandates filing of a specified declaration form, the exemption cannot be proved by other evidence or by any alternate method not contemplated by the rule.