Procedural delay in filing exemption option letter did not defeat substantive notification benefit where disclosure was already made.

Delayed filing of the formal option letter under an exemption notification was treated as a procedural lapse, not a substantive defect, because the assessee had already claimed the notification in the earlier year and had disclosed the relevant option in the classification declaration for the year in question. Since the department already had the necessary particulars and the substantive conditions for exemption were otherwise satisfied, the late formal filing did not defeat the exemption claim. The notification benefit was therefore upheld for the intervening period.

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Issues: Whether delayed filing of the option letter required under the exemption notification denied the assessee the benefit of exemption for the intervening period.

Analysis: The assessee had already availed the notification in the earlier year, had indicated the option in the classification declaration for the relevant year, and the department had the necessary particulars from that declaration. The later filing of the formal option letter was treated as a procedural delay and not as a failure defeating the exemption claim when the substantive requirements were otherwise satisfied.

Conclusion: The delayed filing of the option letter did not deprive the assessee of the notification benefit. The exemption was rightly allowed.

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