Strict compliance with exemption conditions under trade tax notification defeated the claim for industrial exemption.

Conditional fiscal exemption under Section 4-A of the Uttar Pradesh Trade Tax Act required strict and mandatory compliance with the notification dated 22.12.2001. Although exemption notifications may be interpreted to support industrial development, the claimant still had to prove full satisfaction of each stipulated condition. On the facts noted, valid transfer of land within time was not established, the agreement to sell was found doubtful, spot inspection indicated use of old machinery in manufacture, and industrial registration was obtained after the cut-off date. The exemption claim therefore failed, and the concurrent findings of the authorities below were left undisturbed.

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Issues: Whether the revisionist was entitled to exemption under Section 4-A of the Uttar Pradesh Trade Tax Act, 1948, in light of the conditions in the notification dated 22.12.2001, including transfer of land, use of machinery, and registration requirements.

Analysis: The exemption notification was held to be conditional and the conditions prescribed therein were required to be strictly and mandatorily complied with. The Court applied the settled principle that exemption or incentive notifications in fiscal statutes may be construed to advance the object of industrial development, but the claimant must still establish full satisfaction of the stipulated conditions. On the facts, the land was not shown to have been validly transferred to the revisionist within the prescribed time, the agreement to sell was found doubtful, the spot inspection supported the finding that old machinery was used in manufacture, and the industrial registration was obtained beyond the cut-off date.

Conclusion: The revisionist was not entitled to the exemption, and the concurrent findings of the authorities below called for no interference.

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