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Issues: Whether the rejection of the application for way-bills on grounds not contemplated by Rule 110 of the West Bengal Value Added Tax Rules, 2005 was sustainable, and whether the petitioner was entitled to a direction for issue of way-bills.
Analysis: The governing rule prescribed the manner of obtaining way-bills by registered dealers, but did not authorise insistence on production registers, stock registers, inspection at the SEZ unit, or similar additional conditions as prerequisites for issue of way-bills. The rejection was founded on those extra-statutory grounds and was therefore not in accordance with law. At the same time, the authority was not bound to ignore the factual veracity of the petitioner's claim and could insist on reasonable supporting documents in relation to the immediate requirement for way-bills.
Conclusion: The rejection of the way-bill application was set aside, and the petitioner was held entitled to issuance of 10 way-bills, while being directed to produce supporting documents and facilitate inspection.
Ratio Decidendi: An authority exercising quasi-judicial power under a statutory rule cannot reject a claim by importing conditions that the rule itself does not impose.