Exemption certificates for earthquake relief goods may be accepted after delay where the notification permits extension for sufficient cause.

An exemption notification for cement supplied for earthquake relief required a supporting certificate within three months, but also allowed the Assistant Commissioner to extend that period on sufficient cause. The time condition was construed as permitting extension of the original three-month limit, and not as confining relief to a further fixed three months. Because the exemption was intended to support earthquake-hit areas, delayed production of the certificate could not be rejected on a rigid reading of the condition, and the claim for exemption and consequential refund required reconsideration.

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Issues: Whether the certificate required under Notification No. 16/2001-CE for exemption on cement supplied for earthquake relief could be accepted when produced after the prescribed period, and whether the Assistant Commissioner had power to extend the prescribed time.

Analysis: The notification required production of the certificate within three months from the date of removal of the goods, but it also empowered the Assistant Commissioner to extend the said period on sufficient cause being shown. The expression used in the condition showed that the power related to extension of the original three-month period for production of the certificate, and the limit of extension was not confined to a further three months. Since the exemption was meant to facilitate relief in earthquake-hit areas, the subsequently produced certificate ought not to have been ignored merely because it was filed after the initial period.

Conclusion: The certificate could not be rejected solely for delayed production, and the matter had to be reconsidered for grant of the exemption and consequential refund.

Ratio Decidendi: Where an exemption notification expressly empowers the authority to extend the time for producing a certificate, the power is to be construed as extending the original prescribed period on sufficient cause, and a beneficial relief-oriented exemption should not be denied on a rigid or narrow reading of the time condition.

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