Delayed export obligation certificate cannot defeat customs exemption when substantive compliance is already fulfilled.

Delayed production of the Export Obligation Discharge Certificate cannot, by itself, justify denial of customs exemption where the exporter has already fulfilled the export obligation and subsequently obtained the certificate. The delay is treated as a procedural lapse, not a substantive defect, and therefore does not defeat the benefit of the notification. The operative principle is that compliance with the core export obligation is decisive; once that is established, belated submission of the discharge certificate cannot sustain rejection of the exemption claim.

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Issues: Whether the denial of benefit under the customs notifications for delayed production of the Export Obligation Discharge Certificate was sustainable.

Analysis: The appellant had already fulfilled the export obligation and obtained the Export Obligation Discharge Certificate from the DGFT. The only objection was that the certificate was produced belatedly. The delay in producing the certificate was treated as a procedural lapse, and not a ground to deny the substantive benefit of the notifications.

Conclusion: The denial of exemption on the ground of delayed submission of the Export Obligation Discharge Certificate was not sustainable and the issue was decided in favour of the assessee.

Ratio Decidendi: Where the substantive export obligation is fulfilled and the required certificate is subsequently obtained, a delayed production of the certificate constitutes only a procedural defect and cannot by itself defeat the benefit of the exemption notification.

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