Import transaction challenge failed where no specific legal violation was shown and past conduct alone was insufficient.

The Tribunal found no legal infirmity in the import transaction because the Commissioner had already recorded that there was no evidence of any violation of the law governing the consignment. The Revenue's reliance on the exporter's past conduct was insufficient, since it did not identify any specific contravention in relation to the import under review. On that basis, the challenge was found to lack merit and was rejected.

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Issues: Whether the Revenue had shown any legal infirmity or violation in the import transaction so as to justify interference with the Commissioner's order.

Analysis: The Tribunal noted that the Commissioner had recorded a categorical finding that there was no evidence of violation of any law governing the import consignment. The Revenue's appeal relied mainly on the alleged past conduct of the exporter and did not identify any specific contravention in relation to the import in question.

Conclusion: The Tribunal held that no merit was made out in the Revenue's challenge and rejected the appeal.

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