Timely ambulance registration satisfies exemption conditions even if the supporting certificate is produced later.

Exemption under Notification No. 8/96 could not be refused merely because the certificate was produced after the prescribed period, where the vehicles were in fact registered for use as ambulances within time. Condition 29(b) required timely registration as an ambulance or taxi, not simultaneous filing of the certificate. Reading the notification to require earlier production of the certificate would add a restriction not found in the text and unduly narrow the exemption. The late certificate only evidenced compliance, and the refund rejection was set aside.

---

---

Issues: Whether the exemption under Notification No. 8/96 dated 23.07.1996 was available where the vehicles were registered as ambulances within the stipulated period, but the supporting certificate was produced shortly thereafter.

Analysis: Condition No. 29(b) required that the motor vehicle be registered for use solely as a taxi or ambulance within three months of clearance from the factory, or within such extended period as the Assistant Commissioner might allow. The requirement was directed to the fact of registration within time, not to the physical production of the certificate within the same period. A construction insisting that the certificate itself must be furnished within three months would add a restriction not expressed in the notification and would unduly curtail the exemption. Since the vehicles were in fact registered as ambulances within the prescribed time and the certificate evidencing that fact was later produced before the authority, the condition stood satisfied.

Conclusion: The exemption could not be denied on the ground of delayed production of the certificate. The appeal was allowed and the order rejecting the refund was set aside.

---