Substantive exemption conditions prevail over technical non-compliance, but time-barred refund claims remain inadmissible.

Refund claims under the exemption notifications were treated as sustainable where the substantive conditions were met: full duty payment, timely taxi registration, refund to the customer, and filing of the refund claim within six months. The intimation regarding availment of credit was regarded as a procedural requirement of a technical nature, so non-compliance with that formality did not defeat the exemption. However, the portion of the refund claim filed beyond limitation remained time barred and was not admissible.

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Issues: Whether the refund claims under the exemption notifications were sustainable despite non-compliance with the intimation requirement within six months, and whether the time-barred refund amount could be denied.

Analysis: The refund scheme was treated as a beneficial exemption provision. The substantive requirements were identified as full payment of duty, taxi registration within the prescribed time, refund to the customer, and filing of the refund claim within six months, while the intimation about availment of credit was treated as a procedural requirement of technical nature. The Court applied the settled distinction between substantive and procedural conditions, holding that non-observance of a technical procedural requirement does not defeat exemption when substantive conditions are satisfied. At the same time, the refund claim for the amount filed beyond limitation was treated as time barred.

Conclusion: The refund claims were allowed except for the amount found time barred, which was not admissible.

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