Retrospective exemption amendment ties industrial tax benefit to effective registration date, not first sale date.

A retrospective substitution of Section 4A linked industrial exemption to the date Factories Act registration became effective, rather than the date of first sale. Because the amended Explanation operated retrospectively from 12 October 1983, the notified exemption period had to be computed from the effective registration date where registration was granted later. On that basis, the claim for exemption from an earlier date failed and the eligibility certificate was sustained.

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Issues: Whether the petitioner was entitled to exemption from the date of first sale or from the date on which registration under the Factories Act became effective, in view of the amended Section 4A and the retrospective substitution of the Explanation.

Analysis: The amended statutory scheme under Section 4A, as substituted by the U.P. amendment, provided that where registration under the Factories Act is granted with effect from a later date, the unit is entitled to exemption only for the part of the notified period computed from the date the registration becomes effective. The substitution was expressly made retrospective from 12 October 1983, so the later amendment governed the petitioner's claim. Since the petitioner's registration became effective on 15 October 1988, grant of benefit from that date was held to be in accordance with the statute and not arbitrary.

Conclusion: The petitioner was not entitled to exemption from an earlier date, and the order rejecting the review application was upheld.

Final Conclusion: The writ petition failed because the retrospective amendment controlled the entitlement period and the eligibility certificate was sustained on that basis.

Ratio Decidendi: Where an exemption provision is retrospectively substituted to link benefit to the effective date of registration, the entitlement must be determined in accordance with the substituted provision even if the application or original claim arose earlier.

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