Mandatory transitional filing deadlines bar input tax rebate when stock statements are filed after substantial delay.

Transitional input tax rebate under the VAT regime was conditional on furnishing the prescribed stock particulars within the statutory time limit. Applying strict construction of taxing statutes, the HC treated the filing deadline for Form 74 as an integral part of the transitional scheme and not a merely directory requirement. Because the dealer filed the stock statement after substantial delay, the statutory conditions for the concession were not met. The claim to input tax rebate therefore failed, and the denial of rebate with the consequential demand was upheld.

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Issues: Whether the assessee was entitled to input tax rebate on stock held on the date of commencement of the VAT regime despite delayed filing of the prescribed stock statement, and whether the time limit under the transitional provisions was mandatory.

Analysis: The assessment related to the transition from the repealed commercial tax regime to the VAT regime. The relevant saving clause preserved accrued rights and liabilities under the repealed law, but the transitional rebate under Section 73 required the registered dealer to furnish stock particulars within the prescribed period. Rule 80 required filing of Form 74 within the stipulated time, and the record showed a substantial delay in filing. The Court applied the principle that taxing statutes are to be strictly construed and that the grant of input tax credit is a statutory concession subject to fulfillment of the prescribed conditions. The time limit was treated as integral to the transitional scheme and not as a merely directory requirement.

Conclusion: The delayed compliance defeated the claim to transitional input tax rebate, and the denial of rebate and consequential demand was upheld against the assessee.

Ratio Decidendi: Where a fiscal statute grants transitional input tax credit subject to a prescribed time limit for filing the requisite statement, compliance with that time limit is mandatory and the benefit cannot be claimed after substantial delay.

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