Retrospective tax exemption certificate cannot validate an earlier period without statutory authority.

An eligibility certificate for sales tax exemption could not be given retrospective effect to cover an earlier assessment period where there was no statutory authority for such retrospectivity. The court noted that the earlier certificate did not permit production beyond the existing limit, and a later certificate could not validate exemption for expansion or modernisation from a prior period. The concurrent findings of the assessing authority, appellate authority, and Tribunal were found free from legal infirmity, so the exemption claim was rejected.

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Issues: Whether the District Industries Centre had authority to issue an eligibility certificate granting exemption for expansion or modernisation with retrospective effect.

Analysis: The petitioner claimed sales tax exemption on enhanced production capacity on the strength of a later certificate issued by the District Industries Centre. The Court found that the earlier certificate did not authorise production beyond the existing limit and that the subsequent certificate, issued later, could not operate retrospectively to validate exemption for an earlier assessment period. The concurrent findings of the assessing authority, the appellate authority, and the Tribunal disclosed no legal infirmity.

Conclusion: The certificate could not be given retrospective effect, and the issue was answered against the assessee and in favour of the Revenue.

Ratio Decidendi: In the absence of statutory authority, an eligibility certificate granting tax exemption cannot be issued with retrospective effect so as to confer exemption for an earlier period.

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