Tax exemption notifications yield to amended statutory conditions; Form C or Form D compliance governs post-amendment inter-State sales.

A tax exemption granted by notification remains subject to later statutory amendment. After section 8(5) of the Central Sales Tax Act was amended, inter-State sales had to comply with the prescribed requirement of producing Form C or Form D, and the exemption could operate only in line with section 8(4). The notification merely reflected that post-amendment condition and did not retrospectively disturb completed transactions. For the assessment period after the amendment, non-compliance could validly support assessment and related notices, and promissory estoppel could not override the amended fiscal statute.

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Issues: Whether the amended requirement under section 8(5) of the Central Sales Tax Act, 1956, requiring production of declaration in Form C or certificate in Form D, could be applied to the assessee despite the earlier exemption notification and whether the assessment and consequential notices based on non-compliance were valid.

Analysis: The exemption granted in 1998 was a statutory benefit and not an absolute right. After the amendment to section 8(5), the exemption had to operate in conformity with section 8(4), which mandates furnishing of the prescribed declaration or certificate for inter-State sales. The impugned notification merely incorporated that statutory condition for the period after the amendment and did not retrospectively unsettle completed transactions. Since the assessment related to a period subsequent to the amendment, the assessee was required to comply with the revised statutory conditions. The plea based on promissory estoppel could not override the amended fiscal statute, and the proposition notices could not be faulted as objections could still be raised before the assessing authority.

Conclusion: The challenge to the amended notification and the consequential assessment action failed; the assessee was held bound by the post-amendment statutory conditions and the claim for quashing was rejected.

Ratio Decidendi: A tax exemption granted by notification remains subject to subsequent statutory amendment, and for periods after the amendment the assessee must satisfy the mandatory conditions prescribed by the governing statute; promissory estoppel cannot prevent application of the amended law.

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