Strict compliance with prescribed registration conditions governs sales tax exemption claims under the West Bengal regime.

A fiscal exemption under section 39 of the West Bengal Sales Tax Act, 1994 was available only if the prescribed conditions were strictly met, including registration of the small-scale unit with the Directorate of Cottage and Small Scale Industries. The claimant had not produced a permanent registration certificate, and the adverse cancellation order had attained finality, so the eligibility certificate and tax holiday were unavailable under the 1994 regime. The later MSME Development Act, 2006 did not displace the statutory requirements governing the claim, because entitlement had to be tested under the 1994 Act and its rules. The rejection of exemption was therefore sustained.

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Issues: Whether the writ petitioner was entitled to an eligibility certificate and tax holiday under section 39 of the West Bengal Sales Tax Act, 1994 without obtaining the requisite registration with the Directorate of Cottage and Small Scale Industries, and whether the later enactment of the Micro, Small and Medium Enterprises Development Act, 2006 relieved compliance with the statutory conditions under the 1994 Act.

Analysis: Section 39 granted tax holiday only subject to such conditions and restrictions as may be prescribed. The relevant rules required the small-scale industrial unit to be registered with the Directorate of Cottage and Small Scale Industries as a condition for claiming the benefit. The writ petitioner had not produced a permanent registration certificate and the adverse order canceling registration had attained finality. The later MSME legislation did not assist the petitioner because the claim was examined under the 1994 Act and the rules framed thereunder, and the statutory requirements for that regime continued to govern entitlement to exemption.

Conclusion: The petitioner was not entitled to the eligibility certificate or tax holiday under the 1994 Act, and the rejection of the claim was sustained.

Final Conclusion: The challenge failed because compliance with the prescribed registration requirement was a precondition to the tax exemption claim under the governing sales tax regime.

Ratio Decidendi: Where a fiscal exemption is made expressly subject to prescribed conditions, the claimant must strictly satisfy those conditions before the benefit can be granted.

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