Procedural delay in filing exemption statement was not fatal to self-credit where eligibility was otherwise satisfied.

A one-day delay in filing the statement required under an exemption notification was treated as a procedural lapse rather than a substantive breach. The filing requirement formed part of the procedural machinery for availing self-credit under the exemption scheme, and where the notification language matched earlier Tribunal precedent, delayed compliance was not regarded as fatal if the assessee was otherwise eligible. On that basis, the short delay did not justify forfeiture of the option to take credit on own account or denial of the notification benefit.

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Issues: Whether a delay of one day in filing the statement required under the exemption notification was a procedural lapse that could not justify denial of self-credit and the benefit of the notification.

Analysis: The condition for filing the statement by the specified date was treated as part of the procedural machinery for availing self-credit under the exemption scheme. The notification conditions were found to be identically worded to those considered earlier by the Tribunal, where delayed compliance with the filing requirement was held not to be fatal when the assessee was otherwise eligible for the benefit. Following that reasoning, the short delay in submitting the statement did not warrant forfeiture of the option to take credit on own account.

Conclusion: The delay was only a procedural lapse and did not justify denial of self-credit; the assessee succeeded on the issue.

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