Exemption notification compliance: delayed eligibility certificate cannot defeat relief where substantive conditions are otherwise met.

Delay in producing an eligibility certificate does not, by itself, defeat an exemption claim where the substantive conditions of the notification are otherwise satisfied. The Tribunal held that exemption cannot be denied merely because the certificate was filed after the original assessment, so long as the certificate otherwise establishes entitlement. Subsequent production was therefore sufficient to preserve the benefit of the notification.

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Issues: Whether benefit of an exemption notification can be denied merely because the required eligibility certificate was produced after the original assessment.

Analysis: The relevant question was whether delay in production of the certificate defeated the exemption claim, or whether compliance with the substantive requirements of the notification was sufficient. The Tribunal held that where the substantive condition of the notification is otherwise satisfied, the exemption cannot be refused only because the certificate was produced subsequently. The certificate may be accepted if it otherwise establishes entitlement to exemption.

Conclusion: The subsequent production of the certificate did not by itself disentitle the appellant from exemption.

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