Judgment : The Order of the Court is as follows: 1. The petitioner was permitted to bring India the sale proceeds of the goods exported beyond the period of sic months from the end of the previous year and beyond 30-8-1994 up to which date extension had been granted. The assessment year is 1993-94. The petitioner had made a further application for extension of time on 3-10-1995 to extended the time up to 7-1-1995 on which date the sale proceeds had been brought into India. That application was rejected by the Chief Commissioner on 10-1-1996 on the ground that extension cannot be given retrospectively. 2. Section 80HHC(2)(a) of the Income-tax Act, inter alia, empowers the Chief Commissioner to fix the period beyond six months from the end of the previous year within which the exporter should bring in the monies into India. The relevant section reads as under, "80HHC(2)(a) This section applies to all goods or merchandise, other than those specified in clause (b), if the sale proceeds of such goods or merchandise exported out of India are received in, or brought into India by the assessee other than the supporting manufacturer in convertible foreign exchange with a period of six months from the end of the previous year or, where the Chief Commissioner or Commissioner is satisfied (for reasons to be recorded in writing) that the assessee is, for reasons beyond his control, unable to do so within the said period of six months, within such further period as the Chief Commissioner or Commissioner may allow in this behalf." 3. The assessee is required to satisfy the Commissioner that for reasons beyond his control the petitioner is unable to bring the money into India in convertible foreign exchange within a period of six months or within such further period as the Commissioner had allowed and, therefore, further period as the Commissioner had allowed and, therefore, further extension is warranted. The section does not prevent the commissioner from extending the time on more than one occassion. The section does not lay down as a pre-condition that the exporter should have applied for extension before the expiry of six months from the end of the assessment year or that the extension should have been sought before the expiry of the period up to which the time had been extended. The section does not lay down as a pre-condition that the exporter should have applied for extension before the expiry of six months from the end of the assessment year or that the extension should have been sought before the expiry of the period up to which the time had been extended. A very discretion is vested in the Chief Commissioner to fix the period within the exporter is to be permitted to bring the proceeds into India. 4. The Supreme Court of India in the case of CIT v. Ajanta Electricals while construing the meaning of the word extend in section 139(2) of the Act, inter alia, held as under, "We cannot accept the contention raised on behalf of the Revenue that the word extend in the proviso to section 139(2) implies that at time of making the application the time allowed should not have expired. Though the Civil Procedure Code, 1908, by itself does not apply to the proceedings under the Income-tax Act, we see no reason why a principle of procedure evolved for doing justice to a party to the proceeding cannot be called in aid while interpreting a procedural provision contained in the Act ......." 5. these observations of the Apex Court apply with equal force for determining the proper construction to be placed on section 80HHC(2)(a). The provision here fixing the time within which the monies have to be brought into India is a procedural provision. That time can be varied by an order of the Chief Commissioner by extending the period within which the money has to be brought in. The primary object of the section is that the sale proceeds realised from the export of the goods should be brought into India in convertible foreign exchange. It is that primary purpose which should be shown to have been satisfied for the purpose of claiming the benefit granted under section 80HHC. The period within which the monies are to be brought into India is a matter which is governed by the procedural aspect of the section which fixes the time-limit, which time-limits is not but is capable of being extended by the Chief Commissioner. 6. The rules of procedure are not meant to be strait-jackets by applying which the affected persons should be denied relief to which they may be entitled otherwise. 6. The rules of procedure are not meant to be strait-jackets by applying which the affected persons should be denied relief to which they may be entitled otherwise. If the circumstances established by the assessee were such as to warrant the exercise of the discretionary power of the Chief Commissioner, relief is not to be denied on the ground that the application was filed after time granted earlier had expired and the monies were brought into India after such expiry. 7. The order of the Commissioner, therefore, is not sustainable and is set aside. The manner is remanded to the Chief Commissioner for fresh consideration in a accordance with law and the light of the observations made in the course of this order. Consequently, W.M.P. No. 2164 of 1997 is dismissed.