Fuel-efficiency exemption depends on certification date, not prototype testing date, for concessional duty benefit.

Notification No. 462/86 granted concessional duty for fuel-efficient light commercial motor vehicles only on certification by the competent authority. Because the prototype was sent for testing before the fuel efficiency certificate was issued, the exemption could not attach from the testing date. The operative date for the benefit was the date of issue of the certificate, as clarified by the Ministry of Industry. The earlier period therefore remained outside the notification's benefit, and the assessee's claim for exemption from the testing date failed.

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Issues: Whether the benefit of Notification No. 462/86 for fuel-efficient light commercial motor vehicles was available from the date the prototype was sent for testing, or only from the date on which the fuel efficiency certificate was issued.

Analysis: The notification required certification by the competent authority as a condition for availing the concessional rate of duty. The prototype was sent for testing before certification, and the relevant certificate was issued only later. The Ministry of Industry also clarified that the operative date for extending the benefit was the date of issue of the certificate. On this construction, the date of sending the prototype could not be treated as the date from which exemption attached.

Conclusion: The benefit of the notification became available only from the date of issue of the fuel efficiency certificate, not from the date the prototype was sent for testing. The denial of benefit for the earlier period was in law and the assessee's claim failed.

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