Liberal construction of industrial exemption under Section 4-A cannot be defeated by a narrow or technical approach.

Section 4-A of the U.P. Trade Tax Act, 1948, being an incentive provision meant to promote new industries, must be construed liberally. On the facts discussed, the material relied on to deny exemption and an eligibility certificate did not justify rejection of the claim. The rejection orders were therefore unsustainable because exemption intended to encourage industrial development should not be defeated by a narrow or technical approach where the statutory conditions are otherwise satisfied.

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Issues: Whether the petitioners were entitled to exemption and eligibility certificate under section 4-A of the U.P. Trade Tax Act, 1948, and whether the rejection orders were sustainable.

Analysis: Section 4-A is an incentive provision intended to encourage the growth of new industries, and it must receive a liberal construction. On the facts, the material relied upon to deny exemption did not justify rejection of the claim. The controversy was examined in the light of the principle that exemption meant to promote industrial development should not be defeated by a narrow or technical approach.

Conclusion: The petitioners were entitled to relief, and the rejection of exemption was unsustainable.

Ratio Decidendi: An exemption provision enacted to promote new s must be construed liberally, and exemption under section 4-A cannot be denied on an unduly narrow view where the statutory conditions are otherwise satisfied.

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