QCO exemption depends on the shipment-date cutoff, not SIMS registration before that date.

The petitioner imported steel products under ITC-HS Code 7304.

A Ministry of Steel notice dated 19 February 2026 required importers to obtain an Automatic Registration Number (ARN) through the Steel Import Monitoring System (SIMS) between 60 and 3 days before the expected arrival of a consignment; the ARN remained valid for 75 days.

A Ministry order dated 8 April 2026 exempted specified steel imports from mandatory compliance with the Quality Control Order (QCO) where the bill of lading recorded a “shipped on board” date on or before 30 June 2026.

The petitioner’s Thailand consignments were shipped on board on 27 June 2026, and its Ukraine consignment on 26 May 2026; their expected arrivals were in July 2026.

The petitioner applied for ARNs on 3 July 2026, but could not generate them, and the Ministry refused the exemption on the basis that registration had not occurred by 30 June 2026. After an unsuccessful CPGRAMS complaint and appeal, the petitioner challenged the refusal under Article 226 of the Constitution.

1. Whether the petitioner’s consignments qualified for the QCO exemption under the order dated 8 April 2026, given that their bills of lading recorded shipment on board before 30 June 2026.

2. Whether the petitioner was required to obtain an ARN on or before 30 June 2026 to claim that exemption, despite the SIMS notice prescribing a separate registration window tied to the expected arrival date.

Article 226 of the Constitution empowers the High Court to review the impugned administrative decision.

Under the Ministry of Steel notice dated 19 February 2026, an ARN must be sought between 60 and 3 days before the expected arrival of the consignment and remains valid for 75 days; the notice did not require registration by the QCO exemption’s cutoff date.

The order dated 8 April 2026 made QCO exemption dependent on the bill of lading showing a “shipped on board” date on or before 30 June 2026.

Relying on Southern Petrochemical Industries Co. Ltd. v. Electricity Inspector & ETIO & Ors., (2007) 5 SCC 447, the Court stated that an exemption under a valid, unwithdrawn notification may confer an accrued right when its conditions are met.

Under Bombay Chemical (P) Ltd. v. CCE, 1995 Supp (2) SCC 646, an exemption is strictly construed at the point of determining whether goods fall within its terms, but qualifying goods should not then be excluded by a narrow construction.

The Court also considered Commissioner of Customs (Import), Mumbai v. Dilip Kumar & Co., (2018) 9 SCC 1, which places the burden on the claimant to establish entitlement to an exemption.

The Court found that the petitioner’s bills of lading satisfied the express shipment-date condition in the 8 April 2026 order.

The SIMS notice separately fixed the ARN application period by reference to expected arrival and provided for 75-day validity; neither it nor the QCO exemption order required ARN registration by 30 June 2026.

Because the petitioner applied on 3 July—within the prescribed period before the consignments’ expected July arrivals—the Ministry could not add a registration deadline absent from the governing notifications.

The petitioner therefore met the exemption conditions even applying the strict approach to exemptions discussed in Dilip Kumar.

It allowed the petition in terms of prayer clauses (a) and (b), quashed the impugned order dated 10 August 2026, and granted no order as to costs.