Procedural delay in certificate production does not by itself defeat exemption where substantive conditions are satisfied.

Exemption under the relevant notifications cannot be denied solely because the required certificate was produced after clearance of the goods where the substantive conditions for exemption are otherwise satisfied. The Tribunal treated timely production of the certificate as a procedural requirement and held that later compliance did not defeat the claim. It also noted that the lower authorities had not examined whether the certificates covered the quantities issued or whether they were issued by the proper authority, as the claim had been rejected only for delayed production. The matter was therefore remitted for verification of the certificates on merits.

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Issues: Whether exemption under the relevant notifications could be denied merely because the certificate required at the time of clearance was produced after clearance of the goods.

Analysis: The substantive conditions for availing the exemption were found to have been satisfied. The only objection was delayed production of the certificate contemplated by the notifications. The Tribunal followed its earlier decision in the assessee's own case and held that, in a case of this nature, subsequent production of the certificate is not fatal where the requirement is procedural and compliance after clearance does not defeat the exemption claim. The Tribunal also noted that the authorities below had not verified whether the certificates covered the quantities issued and whether they were issued by the proper authority, because the matter had been rejected solely on the ground of delayed production.

Conclusion: The exemption could not be denied merely because the certificate was produced after clearance, and the matter was remitted for verification of the certificates on merits.

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