Renewal of eligibility certificate depends on full-year serially numbered bills and fresh compliance review each period.

Renewal of an eligibility certificate under section 10F was treated as conditional, not automatic, and depended on fresh satisfaction of the prescribed requirements. Rule 48K(2) was read with the overall scheme of the Act and Rules to require separate accounts and serially numbered bills or cash memos for the dealer's full declared accounting year, not a shorter period chosen by the dealer. The serial-numbering requirement operated as a safeguard to confine the benefit to sales of the eligible unit. Earlier grant of the initial certificate did not control renewal, and each renewal had to be examined afresh for compliance during the relevant period.

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Issues: Whether, for renewal of an eligibility certificate under section 10F, rule 48K(2) required serially numbered bills or cash memos to be maintained for the dealer's entire declared accounting year, and whether non-compliance justified refusal of renewal.

Analysis: The renewal of deferment benefit under section 10F was held to be conditional and not automatic. Rule 48C(5) made renewal dependent on application and fulfilment of the prescribed conditions, while rule 48K(2) required a newly set up industrial unit to keep separate accounts and issue serially numbered bills or cash memos for sales of goods manufactured in the unit. Although rule 48K(2) did not expressly mention the continuous period, the provision had to be read with the overall scheme of the Act and Rules, including the dealer's declared accounting year. The requirement of serial numbering was treated as a safeguard to ensure that only the eligible unit's sales were covered, and the dealer could not choose a monthly or other shorter cycle at will. The earlier grant of the initial certificate did not bind the authority considering renewal, because each renewal had to be examined afresh for compliance during the relevant period.

Conclusion: The requirement of serially numbered bills or cash memos applied to the dealer's full accounting year, and the applicant's month-wise serial numbering did not satisfy the condition for the whole renewal period. However, since compliance was shown for part of the applied period, renewal was directed only for the compliant portion, namely 1 January 1994 to 29 January 1994.

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