Substantive refund benefit cannot be denied for procedural lapse where export and duty-paid input use are proved.

Refund of duty on inputs used in exported goods could not be denied merely because the assessee was not registered with Central Excise or had not strictly followed notification procedures. The export of goods was proved by bills of lading, the use of duty-paid inputs in manufacture was established, and the quantity claimed was accepted. In that setting, the Tribunal applied the principle that substantive benefit under an exemption or refund scheme cannot be defeated by mere procedural non-compliance when entitlement and actual export are otherwise proved.

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Issues: Whether refund of duty paid on inputs used in the manufacture or processing of export goods could be denied merely because the assessee had not taken registration with the Central Excise Department and had not strictly followed the procedural requirements under the governing notification and rules.

Analysis: The duty paid inputs were found to have been used in the manufacture of export goods, the exports were proved by the bills of lading, and the quantity of inputs claimed was accepted. In that situation, a minor procedural lapse such as non-registration could not defeat a genuine refund claim where the assessee was otherwise entitled to procure the inputs without payment of duty under the notification. The Tribunal applied the principle that substantive benefit under an exemption or concessional scheme cannot be denied for mere procedural non-compliance when the underlying export and use of inputs are established.

Conclusion: The refund could not be denied on the ground of non-registration or procedural irregularity, and the assessee was entitled to the refund.

Ratio Decidendi: A substantive exemption or refund benefit cannot be denied for mere procedural non-compliance where the claimed use of inputs and actual export of the resultant goods are proved by evidence.

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