Set-off under sales tax law depends on the effective period of the recognition certificate, not its later issue date.

Entitlement to set-off under the Madhya Pradesh General Sales Tax Act depended on the effective period of the recognition certificate, not the later date on which it was issued. Because the certificate operated from 11 December 1990 and covered the period for which set-off was claimed, the dealer was bound by the legal consequences attached to that certificate for that period. A dealer could not rely on the certificate for the relevant period while also claiming a concession unavailable to holders of such a certificate. The set-off was therefore not available for the relevant period, and the withdrawal of the set-off was upheld.

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Issues: Whether the dealer was entitled to claim set-off under section 8(1)(a) of the Madhya Pradesh General Sales Tax Act, 1958 for the relevant period when a recognition certificate under section 16-C of the Act was in force for that period, though issued later.

Analysis: The decisive factor was not the date on which the recognition certificate was issued, but the period for which it was made effective. Since the certificate operated from 11 December 1990 and covered the period during which set-off was claimed, the dealer was bound by the consequences flowing from that certificate. A dealer cannot take the benefits of the certificate for the relevant period and claim a concession that is unavailable to holders of such certificate. The subsequent issue date did not alter the retrospective force of the certificate for the period in question.

Conclusion: The dealer was not entitled to set-off for the relevant period, and the withdrawal of the set-off was .

Ratio Decidendi: Where a recognition certificate is effective for the period of the claim, the dealer is governed by the legal consequences attached to that certificate for that period, irrespective of the later date of its issue.

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