Project exemption certificates and invoices matched on goods description; minor address mismatch was held immaterial.

Exemption under Notification No. 6/2002-CE, 3/2004-CE, 108/95-CE and 10/97-CE was available where the project certificate and invoices matched on the description of goods and established a clear link to the specified project. A different address in the certificate was treated as immaterial because the certificate carried the appellant's name and the supplies were shown to have been made for the intended project purpose. Minor documentary discrepancies were held insufficient to defeat the object of the exemption notifications. The demand was therefore not sustainable and the appellant was entitled to the exemption.

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Issues: Whether the appellant was entitled to exemption under Notification No. 6/2002-CE, Notification No. 3/2004-CE, Notification No. 108/95-CE and Notification No. 10/97-CE despite discrepancies in the project certificates and the invoices, including the mention of a different address.

Analysis: The certificate issued by the project authority and the invoices were found to tally in respect of the description of the goods, establishing the required correlation between the documents. The discrepancy regarding the address mentioned in the certificate was held to be immaterial, since the certificate bore the appellant's name and the goods were shown to have been supplied for the intended project purpose. The denial of exemption on such minor discrepancies would defeat the object of the notifications, which is to exempt supplies made for specified projects when proper certification exists.

Conclusion: The appellant was held entitled to the exemption notifications, and the demand could not be sustained.

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