CESTAT allowed the appeal by way of remand, holding that the...

CESTAT allowed the appeal by way of remand, holding that the substantive condition for exemption under Notification No.27/2012 - provision of services to foreign diplomatic/consular missions - was satisfied by the appellant. Procedural non-compliances (missing numbered invoices/undertakings and unspecified purpose in a few instances) were largely cured by production of certificates from protocol divisions; only six instances remained uncertified. The matter is remitted to the adjudicating authority to verify the submitted certificates and to grant exemption pro tanto where documentary compliance is established. The tribunal emphasized that procedural defects should not defeat the statutory purpose, while reserving disallowance where substantive conditions remain unfulfilled.