Customs exemption depends on registration at the time of import; later registration cannot cure non-compliance absent express retrospective benefit.

A customs exemption under Notification No. 51/96-Cus. was available only if the institution was registered with the prescribed authority on the date of import. Because registration was obtained only after import, the condition precedent was not satisfied and the benefit could not be extended retrospectively. The notification contained no express provision allowing later registration to cure the defect. Accordingly, the exemption claim failed for want of registration on the import date.

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Issues: Whether exemption under Notification No. 51/96-Customs dated 23.07.1996 was available when the institution was not registered with the prescribed authority on the date of import.

Analysis: The notification made registration with the Ministry on the date of import a condition for availing the exemption. The institution obtained registration only after the import had taken place. The notification did not provide for extension of the benefit with retrospective effect, and the exemption could not be claimed on the basis of a later registration.

Conclusion: The exemption was not available to the respondent on the date of import, and the Revenue's appeal succeeded.

Final Conclusion: The impugned order was set aside and the customs exemption claim was rejected for want of the required registration on the import date.

Ratio Decidendi: Where a customs exemption notification makes registration on the date of import a condition for eligibility, the benefit cannot be granted retrospectively on the basis of a later registration unless the notification expressly so provides.

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