Strict compliance with rebate conditions bars tax concession where mandatory certificates are not filed on time.

A tax concession made available under section 4AA subject to conditions in the notification must be claimed by strict compliance with those conditions and time limits. The notification required timely filing of the District Magistrate's certificate and a certificate from an officer not below the rank of Assistant Labour Commissioner to verify the prescribed employee composition. Failure to furnish the District Magistrate's certificate within the stipulated period meant the mandatory requirements were not satisfied, so the rebate was unavailable and the revision failed.

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Issues: Whether the assessee was entitled to rebate under section 4AA despite failure to furnish the District Magistrate's certificate within the time stipulated in the notification.

Analysis: The rebate under section 4AA was granted only under the conditions and restrictions prescribed by the notification issued under section 4A. The notification required the assessee to file, by 31 December of the succeeding assessment year, a certificate of the District Magistrate confirming the category of the employees and a certificate of an officer not below the rank of Assistant Labour Commissioner confirming the prescribed employment composition. The assessee did not furnish the District Magistrate's certificate within the stipulated time and, in fact, failed to comply with the mandatory requirement for the relevant assessment year.

Conclusion: The assessee was not entitled to the rebate under section 4AA, as the statutory and notified conditions were not fulfilled.

Final Conclusion: The claim for rebate failed for non-compliance with the prescribed notification conditions, and the revisions were dismissed.

Ratio Decidendi: Where a tax concession is expressly made subject to specified conditions and time limits, strict compliance with those conditions is mandatory for availing the benefit.

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