Finality of eligibility certificates bars belated correction where no statutory power to review or revise exists.

An eligibility certificate issued under rule 28A of the Haryana General Sales Tax Rules, 1975 could not be reopened, reviewed, modified, or corrected years later in the absence of an express statutory power. The only remedy for any error in the certificate was the appeal provided under rule 28A(5)(f), and that remedy was not pursued within limitation. Because the petitioner had already enjoyed the exemption benefits and the governing Act and Rules contained no provision authorising belated correction, the request for a higher exemption limit and longer exemption period was untenable and the refusal to revise the certificate was upheld.

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Issues: Whether the eligibility certificate issued under rule 28A of the Haryana General Sales Tax Rules, 1975 could be corrected or revised after several years on the ground that it should have reflected a higher exemption limit and longer exemption period.

Analysis: The eligibility certificate had been issued under rule 28A on the basis of the unit's declared entitlement, and the petitioner did not challenge it by filing the statutory appeal within the prescribed period. The application for correction was made after the petitioner had already availed the exemption benefits for years, but the Act and the Rules contained no provision conferring power to review, revise, modify, or correct an eligibility certificate in the manner sought. The only remedy against any error in the certificate was the appeal provided under rule 28A(5)(f), which was not pursued within limitation. In the absence of a statutory provision authorising correction at such a belated stage, the rejection of the request for revision was not illegal.

Conclusion: The prayer for correction or revised issuance of the eligibility certificate was untenable, and the refusal to entertain it was upheld.

Final Conclusion: The writ petition failed because the impugned certificates had attained finality and no statutory mechanism existed to reopen them after expiry of the prescribed appellate period.

Ratio Decidendi: An eligibility certificate issued under a tax incentive scheme cannot be reopened, reviewed, or corrected after the statutory appeal period has expired unless the governing Act or Rules expressly confer such power.

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