JUDGMENT This writ petition has been filed against the order dated March 17, 1989, (annexure 4 to the petition) by which the petitioner's application under section 4-A of U.P. Trade Tax Act for exemption has been rejected as well as against order dated April 16, 1993 rejecting the petitioner's review application. We have heard Shri S. P. Gupta, senior counsel and Shri Rajesh Kumar, learned counsel for the petitioner and the learned Additional Advocate - General for the respondents. A perusal of the order dated April 16, 1993 shows that the petitioner's application for exemption was rejected on the ground that he has not submitted a registered lease deed in respect of the unit for which he was claiming exemption nor did he furnish the proof about the registration under the Factories Act. Learned counsel for the petitioner contended that these requirements are directory and not mandatory, and he has relied upon a decision of this Court in the case of Hindustan Televisions v. State of U.P. 1995 UPTC 516 and also on the decision of this Court in the case of Sahu Stone Crushing Industries v. Divisional Level Committee [1995] 98 STC 66; 1994 UPTC 1. As regards these decisions we have been informed that a similar judgment of this Court in Saraswati Packing Industries v. State of U.P. 1994 UPTC 1033 has been stayed by the Supreme Court and hence the petitioner can derive no benefit from the same, as held by a Division Bench of this Court in the case of Prem Nath Sharma v. State of U.P. Writ Petition No. 999 of 1993 decided on August 17, 1995. It is pertinent to mention that this Court in another decision Amit Plastic Industry v. Divisional Level Committee, Meerut [1995] 96 STC 538; 1994 UPTC 121 had taken a liberal view of the conditions mentioned in section 4-A for claiming eligibility certificate. However, the Supreme Court in State Level Committee v. Morgardshammar India Limited [1996] 101 STC 1; (1995) 8 JT 53 which decision has been followed by the Supreme Court in Divisional Level Committee v. Amit Plastic Industry, Civil Appeal No. 11431 of 1995 decided on December 1, 1995, has overruled the decisions of this Court in the case of Morgardshammar India Ltd. [1996] 101 STC 3 and Amit Plastic Industry [1995] 96 STC 538. The Supreme Court has emphasised that strict construction must be given to the provisions in an exception/exemption because it increases the tax burden on other members of the community. The Supreme Court has also held that if two views of an exemption are possible it should be construed in favour of the State and not in favour of the subject. In the said decision the Supreme Court held that even if the machinery was new exemption cannot be granted if it was acquired for use in any other factory or workshop in India. Thus, in view of the aforesaid two decisions of the Supreme Court which are binding on us under article 141 of the Constitution, we have to hold that the judgments of this Court in the case of Amit Plastic Industry [1995] 96 STC 538 and Morgardshammar India Limited [1996] 101 STC 3 are no longer good law. In the present case it is admitted that there was no registered lease deed for seven years or more. Learned counsel for the petitioner has submitted that the word "registered" is not to be found in section 4-A. In this connection it may be pointed out that section 107 of Transfer of Property Act states that a lease deed of immovable property for more than one year can only be made by a registered document. Thus, registration is a necessary requirement for creating a lease of immovable property for more than one year. If there is no registration of a lease for more than one year, then in the eye of law there is no lease deed at all. Hence, we have to reject the submission of the learned counsel for the petitioner. Learned counsel for the petitioner has relied on a decision of the Supreme Court in the case of Bajaj Tempo Ltd. v. Commissioner of Income-Tax, Bombay City [1992] 196 ITR 188; AIR 1992 SC 1622 for submitting that a liberal interpretation should be given to a provision for encouraging setting up of new industries. Learned counsel for the petitioner has relied on a decision of the Supreme Court in the case of Bajaj Tempo Ltd. v. Commissioner of Income-Tax, Bombay City [1992] 196 ITR 188; AIR 1992 SC 1622 for submitting that a liberal interpretation should be given to a provision for encouraging setting up of new industries. The aforesaid decision did not pertain to section 4-A of the U.P. Trade Tax Act and hence it has no direct application to section 4-A. On the other hand, the decisions of the Supreme Court in State Level Committee v. Morgardshammar India Ltd. [1996] 101 STC 1 and the Divisional Level Committee v. Amit Plastic Industry (Civil Appeal No. 11431 of 1995 decided on December 1, 1995), are directly on section 4-A and hence we have to follow the latter decisions. Hence, we hold that the conditions in section 4-A must be strictly followed before claiming exemption under section 4-A of the U.P. Trade Tax Act. The decisions of this Court taking a contrary view must all be deemed to be not laying down good law in view of the recent Supreme Court decisions. Shri S. P. Gupta, learned counsel for the petitioner urged that vested rights cannot be destroyed by an amendment to the law, and he relied on the decisions in AIR 1935 SC 33 (Sic); AIR 1955 SC 84 (State of Punjab v. Mohar Singh Pratap Singh), [1955] 6 STC 446 (SC); AIR 1955 SC 661 (Bengal Immunity Company Limited v. State of Bihar), (1963) 48 ITR 59 (SC); AIR 1963 SC 1448 (Commissioner of Income-tax v. Amarchand N. Shroff), AIR 1969 SC 568 (Sic); AIR 1973 SC 1016 (Commissioner of Income-tax v. Vadilal Lallubhai), and AIR 1985 SC 1 (Sital Prasad Saxena v. Union of India). In our opinion the said decisions have no application to the present case. It may be noted that U.P. Act No. 28 of 1991 amended section 4-A retrospectively from 1983. Hence we have to deem it that the amended law existed in 1983. A retrospective amendment amounts to a legal fiction, and regarding legal fictions it has been held by Lord Asguith in East End Dwelling Co. Ltd. v. Finsbury Borough Council (1952) AC 109 that if one is to treat an imaginary state of affairs as real then one's imagination must not "boggle" when it comes to the inevitable corollaries of that state of affairs. Ltd. v. Finsbury Borough Council (1952) AC 109 that if one is to treat an imaginary state of affairs as real then one's imagination must not "boggle" when it comes to the inevitable corollaries of that state of affairs. This decision has been approved by our Supreme Court in Commissioner of Income-tax v. Teja Singh [1959] 35 ITR 408; AIR 1959 SC 352 . Hence even assuming that there was any vested right in the petitioner it can be destroyed by a retrospective amendment. For the above reasons, the petition is dismissed. Interim order, if any is vacated. Petition dismissed.