Exemption certificate conditions must be read reasonably where goods otherwise fit the notification and the prescribed format is substantially complied with.

Imported ink falling within the scope of the exemption notification could not be denied relief merely because the DGTD certificate did not use an express recommendation in the prescribed proforma. The certification requirement was treated as substantially complied with, and ambiguity in the prescribed format was construed reasonably in favour of the assessee. The subsequent amendment of the proforma reinforced that construction. The exemption and consequential refund were therefore allowed.

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Issues: Whether the appellant was entitled to exemption and refund under Notification No. 347/86 when the goods were covered by the notification but the DGTD certificate did not expressly contain the recommendation for exemption in the prescribed proforma.

Analysis: The imported ink was found to fall within the scope of Serial 24(i) of the notification. The only dispute concerned compliance with the certificate condition. The certificate had been obtained in the proforma prescribed by the DGTD, and any ambiguity in the wording of that proforma could not be used to defeat the exemption claim. The subsequent amendment of the proforma to include an express recommendation also supported a broader construction of the condition. In these circumstances, the requirement of certification was treated as satisfied for the purpose of the exemption.

Conclusion: The appellant was held entitled to the exemption and consequential refund.

Final Conclusion: The appeal succeeded and the refund claim was allowed with consequential relief according to law.

Ratio Decidendi: Where goods are otherwise covered by an exemption notification, a certificate condition should be construed reasonably and the assessee should not be denied the benefit for ambiguity in the prescribed certification format when the certificate is substantially in compliance.

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