SSI exemption cannot be denied for non-endorsement of factory address where registration otherwise exists and entitlement is substantive.

A mere omission to mention the factory address in the SSI Registration Certificate did not defeat exemption under Notification No. 175/86 where the assessee was otherwise registered as a small scale unit and held an L4 licence covering the relevant premises. The Tribunal treated the non-endorsement of the new address as a procedural irregularity, not a substantive disqualification, and held that exemption eligibility could not be denied on that basis alone. The denial of exemption was therefore unsustainable, and the small scale industry benefit remained available notwithstanding the address omission.

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Issues: Whether the benefit of Notification No. 175/86 could be denied because the factory address where the goods were manufactured was not mentioned in the SSI Registration Certificate.

Analysis: The appellants were admittedly registered as a small scale unit and held an L4 licence covering both gala numbers. The only objection was that the registration certificate mentioned one address, while manufacture and clearance took place from another gala within the same set-up. The Tribunal held that the absence of the new address in the SSI certificate was at most a procedural defect, and that the substantive entitlement to the exemption could not be defeated when the assessee otherwise remained an SSI unit. Reliance was placed on earlier Tribunal decisions holding that a mere change or non-endorsement of address does not automatically extinguish exemption eligibility.

Conclusion: The denial of exemption was unsustainable. The benefit of Notification No. 175/86 was available to the appellants notwithstanding the omission of Gala No. 128 from the SSI Registration Certificate.

Final Conclusion: The impugned orders were set aside and the appeals succeeded, as the address omission was treated as a curable procedural irregularity and not a ground to deny the small scale industry exemption.

Ratio Decidendi: Where an assessee is otherwise registered as a small scale unit, a mere omission or delay in endorsing the factory address in the registration certificate is only a procedural infraction and cannot by itself defeat exemption under the notification.

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