Delayed end-use certificate did not defeat concessional duty exemption where notification imposed no statutory filing deadline.

Concessional duty under exemption notifications was not denied merely because the end-use certificate was filed late. The notifications required the importer to execute a bond securing duty if the goods were not used for the permitted purpose, but they did not impose a statutory time limit for producing the certificate. The time requirement operated only as a bond condition, and later production cured the breach. Accordingly, delayed submission of the end-use certificate did not defeat the exemption claim, and the duty demand was unsustainable.

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Issues: Whether the benefit of concessional duty under the exemption notifications was deniable merely because the end-use certificate was furnished after the stipulated time.

Analysis: The Notifications required the importer to execute a bond securing payment of duty if the goods were not shown to have been used for the permitted purpose. They did not prescribe any specific statutory time limit for filing the end-use certificate. The time requirement was only a condition of the bond. Since the certificates were eventually produced, the breach was treated as curable and the denial of exemption was held unjustified.

Conclusion: The delayed submission of the end-use certificate did not defeat the exemption claim and the demand of duty was unsustainable.

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