Composite exemption conditions must be cumulatively met; one qualifying step cannot replace mandatory pre-cut-off requirements.

A sales tax exemption notification for new industrial units treated "effective steps" as a composite test requiring cumulative compliance with the prescribed pre-cut-off conditions. For a small-scale unit, provisional registration before the cut-off date, fulfilment of the land requirement, and the relevant financial arrangement had to be read together; the word "or" applied only to the alternative financing routes, not to the foundational eligibility conditions. On that construction, later satisfaction of one element could not substitute for missing mandatory steps, and a unit without provisional registration before the cut-off date would not qualify for the exemption.

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Issues: Whether a small-scale industrial unit could claim sales tax exemption under the notification by satisfying only one of the prescribed conditions, or whether the conditions relating to provisional registration, land, and financial arrangements had to be cumulatively satisfied to amount to having taken "effective steps" before the cut-off date.

Analysis: The exemption notification, as amended, applied to new industrial units that had taken effective steps for setting up the unit before 1 January 2000. For a small-scale industrial unit, the scheme required provisional registration prior to the cut-off date, along with the land requirement, and in addition either prior application for outside financial support or, in the case of a self-financed unit, prior purchase orders for plant and machinery, subject to commencement of commercial production by 31 December 2001. Reading the clauses together, the word "or" linked alternative financial arrangements, not alternative substitutes for the foundational requirements. Accepting the view that any one condition alone would suffice would defeat the structure and purpose of the notification and lead to absurd results.

Conclusion: The conditions were cumulative and not alternative. Since the unit had obtained provisional registration only after the cut-off date, it had not taken effective steps within the meaning of the notification and was not entitled to the sales tax exemption.

Final Conclusion: The claim for exemption failed and the challenge to the rejection of exemption was not sustainable.

Ratio Decidendi: Where a tax exemption notification prescribes a composite test for eligibility, the constituent requirements must be satisfied in the manner indicated by the scheme as a whole, and a later compliance with one element cannot substitute for the mandatory pre-cut-off conditions.

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