Procedural delay in filing notification statement cannot defeat substantive exemption when core conditions are otherwise met.

Late filing of the statement required under Notification No. 32/99 was treated as a procedural lapse, not a substantive breach. The assessees had otherwise satisfied the notification's essential conditions and had filed RT-12 returns with the range superintendent. Because the separate statement of duty paid under PLA was only a procedural requirement, the delay could not defeat the exemption. The distinction between substantive mandatory requirements and procedural provisions was applied, and denial of the notification benefit was rejected.

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Issues: Whether late filing of the statement required under Notification No. 32/99 could deny the assessee the substantive benefit of the notification.

Analysis: The notification was held to impose a procedural requirement for filing a statement of duty paid under PLA by the 7th of the following month. The assessees had otherwise satisfied the substantive conditions, and RT-12 returns had been submitted to the range superintendent. A delay in filing a separate statement, by itself, was therefore treated as a procedural lapse that could not defeat the substantive exemption. The view was supported by the principle that a distinction must be drawn between substantive mandatory requirements and procedural provisions.

Conclusion: Late filing of the statement did not justify denial of the substantive benefit under the notification; the Revenue's challenge failed.

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