Exemption certificate binds the taxing authority; contrary notice issued without jurisdiction and quashed.

An assessing authority cannot ignore an exemption certificate issued by the competent screening committee and proceed on a contrary view. Where the certificate expressly grants 75 per cent exemption and requires payment of only 25 per cent tax, the taxing officer must act consistently with that certificate unless it is corrected or cancelled by the competent committee under the prescribed procedure. A notice issued on an assumption of lesser exemption is therefore beyond jurisdiction and liable to be quashed.

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Issues: Whether the taxing authority could issue notice proceeding on a view contrary to the exemption certificate granted by the competent screening committee.

Analysis: The exemption certificate expressly granted 75 per cent exemption and required deposit of only 25 per cent tax. Once such a certificate was issued by the District Level Screening Committee, the Commercial Taxes Officer could not ignore it or assume a lesser exemption on his own. If the authority was aggrieved by the grant of exemption, the proper course was to seek correction or cancellation through the competent committee in accordance with the prescribed procedure. A notice issued on a contrary assumption was therefore beyond jurisdiction.

Conclusion: The notice was without jurisdiction and liable to be quashed.

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