been invoked in this case. That is a power to relax. If the Central Government is satisfied that in relation to the export of any goods, the exporter or his authorised agent has, for reasons beyond his control, failed to comply with any provisions of these Rules and has thus, been entitled to drawback, the Central Government after considering the representation, if any, made by such exporter or his agent record reasons in writing and exempt the exporter or agent from the provisions of such Rule and allow drawback in respect of such goods. Mr. Sridharan submits that there was nothing which can prohibit the Central Government and in this case from exercising this power to relax. The power to relax was invoked by the Petitioners for bonafide reasons. They could have made a supplementary claim only because of the stand which was taken by the authorities and in pursuance of the show cause notices and the order made thereon. Thus, if the stand is changed by the Assessee and on account of interpretation placed on certain Rules, then, such subsequent change can be a sufficient cause for the delay. The subsequent events as well enable the exercise of the powers to relax because the parties like the Petitioners have acted bonafide. The Petitioner's case may not fall strictly in the Rule 15 but the power under Rule 17 is not circumscribed and in that regard Mr. Sridharan has placed reliance upon a passage from the well known work, namely, Administrative Law by Sir William Wade Eighth
