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Issues: Whether the benefit of the customs exemption notification could be denied for late production of the prescribed certificate of origin and late formal claim, where the country of origin was disclosed in the import documents and the certificate was produced before final assessment.
Analysis: The notification and the country of origin rules were required to be read together, but the decisive question was whether the importer had substantially satisfied the condition that the Assistant Collector be satisfied about the origin of the goods. The import documents consistently showed Morocco as the country of origin, a certificate of origin had been filed before removal and the prescribed form was produced before final assessment. The distinction between removal and clearance for home consumption was material, and the final assessment stage was the point at which customs control ceased. Applying the settled principle that a substantive benefit should not be denied for minor procedural lapses, the absence of strict contemporaneous compliance in form did not defeat the claim.
Conclusion: The benefit of the exemption notification could not be denied, and the procedural lapse in claiming the benefit and filing the prescribed certificate later did not justify refusal of the concession.