Strict construction of exemption notifications denies entry tax relief where mandatory eligibility conditions are not fully satisfied.

Exemption from entry tax could not be claimed under a general notification where the assessee failed to satisfy the mandatory conditions of a linked special exemption notification. The special notification required the stipulated investment, which was admittedly not made, and the general notification also incorporated eligibility requirements relating to a "new industrial unit" and certification under the linked notification. Exemption provisions are construed strictly, and a claimant must bring itself squarely within every prescribed condition before obtaining the benefit; the assessee therefore was not entitled to the exemption.

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Issues: Whether the assessee was entitled to exemption from entry tax under the general notification despite not satisfying the conditions of the special exemption notification issued in its favour.

Analysis: The exemption under the special notification was conditional upon making the stipulated investment, and the assessee admittedly did not satisfy that condition. The general exemption notification also made eligibility dependent on the meaning of "new industrial unit" and on certification under the linked notification, so the assessee had to satisfy those incorporated requirements as well. Exemption notifications are construed strictly, and the assessee must bring itself squarely within all prescribed conditions before claiming the benefit.

Conclusion: The assessee was not entitled to exemption from entry tax.

Ratio Decidendi: A claimant to exemption must strictly satisfy every condition of the notification, and failure to meet a mandatory eligibility requirement disentitles it from the exemption.

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