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    <title>2017 (12) TMI 1231 - BOMBAY HIGH COURT</title>
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    <description>Rule 57R(3) of the Central Excise Rules, 1944 was treated as permitting credit on capital goods acquired on lease even where reimbursement of the excise duty component to the financing company had not yet occurred. The certificate requirement in the prescribed procedure was held to be procedural rather than a substantive condition precedent, and the later omission of that stipulation in the amended rule supported that reading. On limitation, the notice invoking disallowance of credit was not accepted as falling within the extended period, and the connected penalty under Section 11AC could not survive on the same footing.</description>
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