Strict construction of EV tax exemption denied refund where vehicle was purchased before the policy date and later registered.

An exemption for electric vehicles under the Uttar Pradesh Electric Vehicle Manufacturing and Mobility Policy, 2022 required both purchase and registration in Uttar Pradesh from the policy date. A hybrid vehicle purchased before that date did not satisfy the exemption condition, even though it was registered later in the State. The court applied strict construction to the exemption notification and held that mere post-policy registration could not cure the earlier purchase. The refund claim therefore failed because the vehicle remained outside the specified eligibility criteria, and tax paid when chargeable was not refundable on the basis asserted.

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Issues: Whether the petitioner was entitled to refund of one-time tax paid on a hybrid vehicle on the ground that the vehicle fell within the exemption granted for electric vehicles purchased and registered in Uttar Pradesh from the date of the Uttar Pradesh Electric Vehicle Manufacturing and Mobility Policy, 2022.

Analysis: The exemption language required both purchase and registration of the vehicle in Uttar Pradesh from the date of the Policy, 2022. The vehicle was purchased before that date and tax had been paid when it was otherwise chargeable. Mere registration after the policy date did not satisfy the exemption conditions. The eligibility requirements for an exemption notification are to be construed strictly.

Conclusion: The petitioner was not entitled to refund of the tax, and the claim for exemption failed.

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