Doctrine of substantial compliance could not override mandatory timelines for Excise Special Rebate

Cent Ply Vs Commissioner CGST And CX Guwahati (Gauhati High Court) Conclusion: Notification No. 20/2007-CE did not require an Eligibility Certificate as a condition precedent for fixation of special rate of rebate. Since the application was filed eyond the statutory time limit, the claim was barred by limitation. Hence, doctrine of substantial compliance could not override mandatory timelines. Held: Assessee was a newly established industrial unit engaged in the manufacture of plywood, block board, and flush doors, classifiable under Chapter Sub-Heading 44 of the Central Excise Tariff Act, 198...