Contemporaneous test report governs customs exemption for crude palm oil; delayed laboratory results cannot override it without reliable basis.

Imported crude palm oil was found entitled to customs exemption because the contemporaneous initial test report showed carotenoid value within the prescribed range. The later laboratory result, obtained after delay and from a different sample source, could not displace the first report absent a reliable basis to reject it, especially where the variation was only marginal. On that reasoning, denial of the exemption was not sustainable and the appellate authority's grant of benefit was maintained.

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Issues: Whether the imported crude palm oil was entitled to exemption under the relevant customs notification on the basis of the initial test report, despite later laboratory results showing a lower carotenoid value.

Analysis: The goods were sampled at the time of import and the initial test showed carotenoid value within the prescribed range. Subsequent samples taken from the shore tank and the delayed report from CRCL were relied on to deny the exemption. The delay between import and the later test was material, and there was no sufficient basis to discard the initial test report, particularly when the later variation was marginal and the first testing conformed to the notification requirements.

Conclusion: The goods were entitled to the exemption, and the denial of benefit was not sustainable.

Final Conclusion: The revenue challenge failed, and the exemption granted by the appellate authority was maintained.

Ratio Decidendi: Where imported goods satisfy the exemption condition on the basis of the contemporaneous initial test, a later delayed test result cannot displace that entitlement absent a reliable basis to reject the first report.

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