Exemption notifications are confined to sales within the notified period, and post-expiry sales remain taxable with interest.

Exemption under section 4A of the U.P. Trade Tax Act, 1948 applied only to turnover of sales made within the notified exemption period, so goods manufactured during that period but sold after expiry did not qualify for exemption. The plain language of the notification could not be extended beyond the period fixed in the eligibility certificate, and the post-expiry sales were taxable. Once tax became payable on those sales and remained unpaid, interest under section 8(1) followed because the default was not shown to be a bona fide dispute. The revision therefore failed and both tax and interest were sustained.

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Issues: (i) Whether goods manufactured during the exemption period but sold after expiry of that period remained eligible for exemption under section 4A of the U.P. Trade Tax Act, 1948 and the relevant notification. (ii) Whether tax on the post-expiry sales could be treated as admitted tax so as to justify interest under section 8(1) of the U.P. Trade Tax Act, 1948.

Issue (i): Whether goods manufactured during the exemption period but sold after expiry of that period remained eligible for exemption under section 4A of the U.P. Trade Tax Act, 1948 and the relevant notification.

Analysis: Section 4A(1) authorises exemption only on the turnover of sales for the specified period. The notification granted exemption on sales of the notified goods for the period fixed in the eligibility certificate. The relevant period had expired before the disputed sales were made, and the exemption was linked to the sale turnover during the specified period, not merely to manufacture during that period. The language being plain and unambiguous, no wider construction could extend the exemption beyond the notified period.

Conclusion: The sales made after expiry of the exemption period were not entitled to exemption.

Issue (ii): Whether tax on the post-expiry sales could be treated as admitted tax so as to justify interest under section 8(1) of the U.P. Trade Tax Act, 1948.

Analysis: Once the exemption period ended, tax became payable on the turnover of sales. The assessee's failure to deposit tax was at its own risk and the dispute did not amount to a bona fide contest in the facts found. Since the tax was lawfully payable and remained unpaid within time, interest under section 8(1) followed.

Conclusion: Interest under section 8(1) was rightly levied.

Final Conclusion: The revision was found to be without merit, and the levy of tax as well as interest was sustained.

Ratio Decidendi: Where exemption under a taxing notification is granted for a specified period on the turnover of sales, the exemption cannot be extended to sales made after expiry of that period on the basis that the goods were manufactured earlier during the exemption period; clear exemption provisions must be construed according to their plain terms.

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