Export rebate requires verification of duty-paid goods through records, even after processing before export.

Rebate of central excise duty on exported goods cannot be refused merely because the exported article was a processed product if the duty-paid goods can still be identified and shown to have been exported. Rule 12 of the Central Excise Rules, 1944 requires the authority to satisfy itself from the records that the duty-paid chassis were in fact exported, and documentary correlation through chassis numbers and shipping bills is material to that inquiry. Where such verification is feasible, rejection on the sole ground that the exported goods were motor vehicles after body building is unsustainable, and the rebate claim must be reconsidered on fresh verification.

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Issues: Whether rebate of central excise duty paid on chassis could be denied merely because the exported goods were motor vehicles after body building, and whether the matter required fresh verification of the chassis numbers from the shipping records.

Analysis: Rule 12 of the Central Excise Rules, 1944 permits rebate of duty on excisable goods exported outside India, and also empowers the Collector to allow the claim where he is satisfied that the duty-paid goods were in fact exported. The decisive question was therefore whether the chassis manufactured and cleared by the petitioner could be identified from the shipping bills and correlated with the exported motor vehicles. Since the parties accepted that such verification was possible on the basis of chassis numbers, the earlier rejection on the ground that the exported goods were motor vehicles and not chassis could not be sustained without such verification.

Conclusion: The rejection orders were set aside and the competent authority was directed to pass a fresh order after verifying from the records whether the duty-paid chassis manufactured by the petitioner had been exported as motor vehicles.

Final Conclusion: The petitioner obtained substantive relief by securing reconsideration of the rebate claim on the basis of documentary verification, and the matter was remitted for fresh decision.

Ratio Decidendi: Rebate of duty on exported excisable goods cannot be denied where the authority can verify that the duty-paid goods were in fact exported, even if the exported article has undergone processing before export.

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