2007 (6) TMI 446

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..... r the Appellant submitted that for the delayed submission of the amended certificate, entitlement to the exemption was denied. He submitted that original certificates were submitted duly but in view of delay by the Naval Authorities to issue an amended certificate, the appellant was deprived of the benefits. In support of his contention, he relied on the judgments of the Hon ble High Court of Guja .....

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..... atory conditions in full and substantially complied with the directory condition. Even at the cost of repetition, we reiterate that there is no dispute that sufficient proof was furnished, if belatedly, by the petitioner regarding payment of the due money in the aforesaid fund. 2. The ld. JDR submitted that the Notification which was relied upon has not granted them benefit for which the author .....

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..... ficate filed belatedly should not take away the benefit accrued. There is no question of any dispute on the notification itself. Therefore, the citation of Revenue is of no help to them. The only dispute being related to the condition prescribed by notification that was to be complied. The condition being submission of the certificate from Naval Authority and that having been fulfilled, denial of .....

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