- Taxpayer is entitled for exemption if conditions are fulfilled
- Conditions can be mandatory or directory, courts have condone violation of directory conditions
- It is based on the effect of non compliance
- SC in Hari Chand Shri Gopal case led that
- Conditions which are a matter of substance is mandatory; & one which are mere convenience are directory
- E.g. reporting of details of exemption also being a pre-condition to claim exemption is directory
- However, in Wirpo’s case, SC considered filings of declaration as a mandatory condition
- The matter is again debatable between Wirpo’s case and other jurisprudence
