Exemption under Notification No. 12/2012 sustained where factual compliance and undertaking to refine imported oil supported assessee's claim.

Exemption under Notification No. 12/2012 was upheld because the respondent satisfied the notification conditions on the facts, including an undertaking to refine the imported crude palm oil before release and to permit departmental supervision. The High Court accepted the Tribunal's view and noted support from prior decisions involving a similar exemption notification. Departmental circulars did not override this factual compliance, and the Court found no substantial question of law arising for consideration. The appeal was therefore rejected and the exemption benefit sustained in favour of the assessee.

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Issues: Whether the respondent was entitled to exemption under Notification No. 12/2012 dated 17-3-2012, and whether any substantial question of law arose for consideration.

Analysis: The respondent's entitlement to exemption was upheld on facts under the relevant notification. The Court accepted the view taken by the Tribunal and found support in prior High Court decisions dealing with a similar exemption notification. The appellant's reliance on departmental circulars did not displace the conclusion that the respondent satisfied the notification requirements, and the respondent also furnished an undertaking to comply with the condition of refining the imported crude palm oil before release and to permit departmental supervision.

Conclusion: The respondent was held eligible for the exemption benefit, and no substantial question of law arose. The appeal was rejected in favour of the assessee.

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