Strict compliance with tax exemption conditions defeats refund claim where essential sale, delivery and payment requirements were unmet.

A tax exemption notification must be strictly complied with, and exemption or refund fails where the essential conditions are not met. The notification required sale, delivery and payment at the Mahotsava site, but the vehicle purchase here involved advance payment before the notification date, loan sanction, delivery and first registration at Allahabad, not at Safai. Those facts meant the material conditions were not satisfied, so the exemption claim failed. The challenge to the temporary registration and loan-related conditions under Article 14 did not assist, because non-compliance with the other mandatory requirements was independently fatal to relief.

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Issues: (i) Whether the petitioner satisfied the conditions of the notification granting trade tax exemption for purchase of a vehicle at the Safai Mahotsava so as to claim exemption and refund of tax. (ii) Whether conditions requiring temporary registration at Safai and payment linked to loan from a financial institution at Safai were arbitrary and violative of Article 14 of the Constitution of India.

Issue (i): Whether the petitioner satisfied the conditions of the notification granting trade tax exemption for purchase of a vehicle at the Safai Mahotsava so as to claim exemption and refund of tax.

Analysis: The exemption under the notification was available only if the sale, delivery and payment were made at the site of the Mahotsava and the other stated conditions were fulfilled. The petitioner had made advance payment before the notification date, the loan was sanctioned at Allahabad, the vehicle was delivered at Allahabad, and the first registration was also obtained at Allahabad. On these facts, the essential conditions of the exemption were not satisfied.

Conclusion: The petitioner was not entitled to the exemption or refund.

Issue (ii): Whether conditions requiring temporary registration at Safai and payment linked to loan from a financial institution at Safai were arbitrary and violative of Article 14 of the Constitution of India.

Analysis: The condition regarding temporary registration was treated as consistent with the scheme of vehicle registration under the Motor Vehicles Act, 1988. As to the loan-related condition, the Court indicated that even if it were read strictly or assumed to be unreasonable, the petitioner still could not obtain relief because he had failed to comply with the other essential conditions of the notification.

Conclusion: No relief followed on this challenge, and the question of arbitrariness did not alter the result.

Final Conclusion: The exemption claim failed because the petitioner did not comply with the material conditions attached to the tax exemption notification.

Ratio Decidendi: A tax exemption notification must be strictly complied with, and non-fulfilment of the essential conditions defeats the claim to exemption even if one condition is alleged to be invalid.

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