Exemption for exhibition goods cannot be refused merely because the required certificate was produced after clearance.

Exemption under Notification No. 215/84-C.E. could not be denied solely because the State Government certificate was produced after clearance of the goods, where the goods were in fact cleared for an approved exhibition and the substantive notification conditions were satisfied. The record showed exhibition use, and the Revenue did not dispute that the machines were cleared for that purpose. Delayed production of the certificate did not negate compliance with the exemption requirement, so the benefit of the notification remained available to the assessee.

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Issues: Whether the benefit of Notification No. 215/84-C.E. dated 9-11-1984 could be denied merely because the certificate from the State Government was produced after clearance of the goods for exhibition purposes.

Analysis: The notification permitted exemption where the goods were cleared for an approved or sponsored exhibition on production of the requisite certificate from the Central or State Government or the Trade Fair Authority. The certificate was in fact obtained from the State Government and the record showed that the goods were cleared for exhibition purposes. The later production of the certificate did not negate the substantive satisfaction of the notification condition, and the Revenue did not dispute that the machines were cleared for exhibition.

Conclusion: The exemption under Notification No. 215/84-C.E. was rightly allowed and the Revenue's challenge failed.

Final Conclusion: The appeal was not accepted on the exemption issue, and the benefit of the notification remained available to the assessee in respect of the machines cleared for exhibition purposes.

Ratio Decidendi: Where the substantive conditions of an exemption notification are satisfied and the requisite certificate is ultimately produced, delayed production of the certificate does not by itself justify denial of the exemption.

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