https://www.taxtmi.com/caselaws?id=43909 An excise exemption notification requiring an undertaking at clearance, payment into the Fertilizers Pool Equalization Fund, and timely production of payment proof was construed as containing substantive and procedural conditions. The undertaking and payment were substantive requirements within the assessee's control, while furnishing proof was treated as a procedural, directory step dependent partly on external factors. Applying a liberal construction to exemption notifications and reading the instrument as a whole, the Court held that substantial compliance with the proof requirement was enough where the delay was not due to negligence. The assessee was therefore entitled to the exemption, and duty demands based only on delayed proof were invalid. en-us Thu, 27 Jun 1991 00:00:00 +0530 Mon, 21 Jun 2010 18:04:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=43909 An excise exemption notification requiring an undertaking at clearance, payment into the Fertilizers Pool Equalization Fund, and timely production of payment proof was construed as containing substantive and procedural conditions. The undertaking and payment were substantive requirements within the assessee's control, while furnishing proof was treated as a procedural, directory step dependent partly on external factors. Applying a liberal construction to exemption notifications and reading the instrument as a whole, the Court held that substantial compliance with the proof requirement was enough where the delay was not due to negligence. The assessee was therefore entitled to the exemption, and duty demands based only on delayed proof were invalid. Case-Laws Central Excise Thu, 27 Jun 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=43909