Exemption certificate protection bars assessment proceedings while the certificate remains valid and uncancelled.

A valid and unmodified exemption certificate under section 4-A protected the covered unit from assessment during its currency, so the competent authority could not lawfully initiate assessment proceedings or issue notices under the U.P. and Central Sales Tax laws. Because the certificate remained uncancelled and operative, the assessment action was inconsistent with that statutory protection. The notices were therefore quashed, and the respondents were restrained from proceeding with assessment so long as the certificate remained valid.

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Issues: Whether assessment proceedings could be initiated and notices issued during the currency of a valid exemption certificate granted under section 4-A of the U. P. Sales Tax Act.

Analysis: The certificate granted to the petitioner remained unmodified and un-cancelled. During its currency, the competent authority could not proceed to assess the unit covered by the certificate. Since the respondents nonetheless initiated assessment proceedings by issuing notices under the U. P. and Central Sales Tax laws, the action was inconsistent with the protection flowing from the exemption certificate.

Conclusion: The initiation of assessment proceedings was impermissible. The notices were quashed and the respondents were restrained from proceeding with assessment so long as the certificate remained valid.

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