Exemption claim cannot be rejected as an afterthought without finding on eligibility; matter remanded for fresh consideration.

Eligibility for exemption under Notification No. 72/86 had to be decided on merits, and the claim could not be rejected merely as an afterthought without a finding on substantive entitlement. As the adjudication order omitted any determination of eligibility and denied relief only on timing grounds, the matter required fresh consideration. The order-in-original was set aside and the claim was remanded to the jurisdictional adjudicating authority for reconsideration.

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Issues: Whether the appellants were entitled to exemption under Notification No. 72/86 in respect of watch straps, and whether the claim could be rejected merely as an afterthought without a finding on eligibility.

Analysis: The adjudication order did not record any finding on the appellants' eligibility under Notification No. 72/86 and instead rejected the claim as an afterthought. Where eligibility to an exemption notification exists, the benefit cannot be denied merely because the claim was made at a later stage. In the absence of a finding on the substantive question of eligibility, the matter required reconsideration by the adjudicating authority.

Conclusion: The order-in-original was set aside and the matter was remanded to the jurisdictional adjudicating authority for fresh consideration of the claim for exemption under Notification No. 72/86.

Ratio Decidendi: An exemption claim cannot be rejected solely as an afterthought when the adjudicating authority has not determined the assessee's eligibility to the notification; such an omission requires remand for decision on merits.

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