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    <description>Fulfilment of export obligation in substance was treated as sufficient for exemption under Notification No. 204/92-Cus, and the absence of a contemporaneous redemption certificate was regarded as only a technical defect because the certificate was later issued and no material showed the exports were in doubt. By contrast, reversal of MODVAT credit on inputs used in exported goods was not conclusively proved on the record, so the factual position required verification by the original authority, with an opportunity to cure any non-reversal if established. The exemption issue therefore turned on substance over form, while the credit-reversal issue was left for further factual ascertainment.</description>
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