Subsequent production of prescribed certificate can satisfy exemption conditions where the substantive requirement is otherwise proved.

Exemption under Notification No. 262/86-C.E. was available for solvent extracted refined groundnut oil where the prescribed certificate, though not produced at clearance or original adjudication, was later filed before the appellate authority and covered the relevant period and quantity. The earlier non-production was treated as a procedural lapse because the substantive condition of the notification stood satisfied by the later certificate and supporting records. On that basis, the exemption was held admissible and the demand and penalty were set aside.

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Issues: Whether the assessee was entitled to exemption under Notification No. 262/86-C.E. for solvent extracted refined groundnut oil when the prescribed certificate was produced after clearance but covered the relevant period and quantity.

Analysis: The notification granted exemption to processed fixed vegetable oils subject to specified conditions, including production of a certificate from the designated authority confirming manufacture from solvent extracted oil. The certificate was not produced at the stage of clearance or original adjudication, but was produced later before the appellate authority and covered the entire disputed quantity for the relevant period. The absence of the certificate at the earlier stage was treated as a procedural lapse, and not as a ground to deny exemption where the substantive condition stood satisfied by the later certificate and supporting records.

Conclusion: The exemption under Notification No. 262/86-C.E. was held admissible and the demand and penalty were set aside in favour of the assessee.

Ratio Decidendi: Where an exemption notification requires a certificate to establish fulfilment of a substantive condition, subsequent production of the prescribed certificate covering the disputed period and quantity satisfies the requirement and mere non-production at the initial stage does not by itself defeat the exemption.

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