Exemption cannot be denied for belated CT 2 certification when substantive entitlement is otherwise established.

Exemption under Chapter X could not be denied merely because the CT 2 certificate and related procedural steps were completed after clearance, where the substantive conditions were otherwise satisfied. The goods had been received from the Government Mint, and the assessee held the relevant L-6 licence or CT 2 certificate. The Tribunal treated the defect as a procedural lapse, not a substantive failure, and noted that the department had already accepted the benefit for some clearances. Delayed production of the certificate was therefore not fatal, and the exemption remained available.

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Issues: Whether the benefit of the exemption notification could be denied merely because the CT 2 certificate and related procedural requirements were completed after the clearances, when the substantive conditions for exemption were otherwise satisfied.

Analysis: The Tribunal noted that the goods were received under Chapter X from the Government Mint and that the assessee held the relevant L-6 licence or CT 2 certificate. The denial rested only on the timing of the certificate and the clearances. Relying on the settled principle that exemption cannot be refused on a mere technical or procedural lapse when the substantive entitlement is established, the Tribunal held that delayed production of the certificate was not fatal. The record also showed that the department had already accepted the benefit for some clearances, reinforcing that the dispute was procedural and not substantive.

Conclusion: The exemption benefit could not be denied on the ground of belated CT 2 certification or procedural non-compliance, and the assessee was entitled to the benefit.

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