Procedural delay in exemption intimation did not defeat substantive eligibility, so the exemption benefit remained available.

Delayed intimation of the option for self-credit under an exemption notification was treated as a procedural lapse, not a ground to deny the exemption benefit. The assessee's substantive eligibility was undisputed, and the only issue was non-compliance with the intimation requirement within time. Applying the principle that procedural conditions should not defeat a substantive exemption where the underlying requirements are satisfied, the Tribunal treated the requirement as directory in this context. The consequence was that the exemption remained available despite the delay, and the Revenue's challenge failed.

---

---

Issues: Whether delayed intimation of the option for self-credit under the exemption notification was a mere procedural lapse so as to preserve the assessee's entitlement to the exemption benefit.

Analysis: The Tribunal held that the assessee's eligibility to the exemption was not in dispute and the controversy was confined to delayed compliance with the option/intimation requirement. Relying on prior Tribunal decisions and the principle that procedural requirements should not defeat a substantive benefit otherwise available under an exemption notification, the Tribunal treated the condition as directory rather than mandatory in a manner that would forfeit the benefit. It also followed the consistent view that where the substantive conditions are satisfied, delay in filing the required statement or intimation does not justify denial of exemption.

Conclusion: The delayed intimation was only a procedural lapse and did not disentitle the assessee from the exemption benefit; the Revenue's appeal failed.

---