SSI exemption upheld where unrebutted official certificates showed the unit was in a rural area during the relevant period.

SSI exemption under Notification No. 8/2003-CE was available because the manufacturing unit was shown, through unrebutted certificates from the Municipal Corporation, Naib Tehsildar and Village Sarpanch, to have been situated in Village Rampur outside municipal limits during the relevant period. As the Revenue produced no contrary material to dislodge those certificates, the unit was treated as being in a rural area before 17.03.2010, and the exemption claim succeeded.

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Issues: Whether the respondent was entitled to small scale industry exemption under Notification No. 8/2003-CE dated 01.03.2003 for the period when the manufacturing unit was situated in Village Rampur before 17.03.2010.

Analysis: The location of the unit before 17.03.2010 was supported by certificates issued by the Municipal Corporation, the Naib Tehsildar, and the Village Sarpanch, all indicating that Village Rampur was a rural area and outside the municipal limits till that date. No contrary material was produced by the Revenue to dislodge those certificates. On that basis, the unit was treated as having been located in a rural area during the relevant period, and the exemption claim was found to be available.

Conclusion: The respondent was held entitled to the benefit of Notification No. 8/2003-CE dated 01.03.2003, and the Revenue's challenge failed.

Ratio Decidendi: Where the assessee establishes through unrebutted official certificates that the manufacturing unit was located in a rural area during the relevant period, SSI exemption cannot be denied on a contrary and unproved location claim.

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