Strict compliance with exemption conditions governs sales tax relief; production after the cut-off date defeated eligibility.

Sales tax exemption under the relevant notifications was available only on strict compliance with the prescribed conditions, including commencement of commercial production before 1 January 2000. As the industrial unit obtained provisional registration only on 14 August 2000 and began production after the cut-off date, the essential eligibility requirement was not met. The exemption provisions were construed strictly, and promissory estoppel could not be invoked to override the statutory notification conditions. The denial of sales tax exemption was therefore upheld.

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Issues: Whether the appellant was entitled to sales tax exemption under the relevant exemption notifications despite having obtained provisional registration and commenced commercial production after the stipulated cut-off date.

Analysis: The claim for exemption depended on fulfilment of the mandatory conditions prescribed in the notifications governing sales tax exemption for small-scale industrial units. The decisive requirement was commencement of commercial production before 1 January 2000. The appellant's provisional registration was obtained only on 14 August 2000 and commercial production commenced after the cut-off date, so the essential condition was not satisfied. The exemption provisions were required to be construed strictly, and the Court found no factual basis to invoke promissory estoppel because the statutory and notification conditions for the benefit had not been met.

Conclusion: The appellant was not entitled to sales tax exemption, and the denial of exemption was upheld.

Ratio Decidendi: A tax exemption can be availed only on strict fulfilment of the mandatory conditions prescribed by the exemption notification, and the Court cannot direct grant of exemption in disregard of such conditions.

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