Country of origin certification prevails where contrary evidence is inconclusive, preserving concessional customs benefit and defeating misdeclaration.

Where the designated origin authorities certified Sri Lanka as the country of origin and the contrary laboratory or institutional material was inconclusive, the customs benefit could not be denied on the basis of reused packing markings or unsubstantiated document objections. The record also supported the genuineness of the transaction through banking channels, and selective denial across similarly placed containers was not justified without a reasoned basis. On that footing, the misdeclaration allegation failed and the concessional benefit under the customs notification was upheld.

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Issues: Whether the imported areca nuts were of Sri Lanka origin so as to qualify for the concessional benefit under the customs notification, and whether the allegation of misdeclaration in origin and documentation was sustainable.

Analysis: The laboratory and institutional reports did not establish Indonesian origin, while the designated Sri Lankan authorities certified the country of origin. The markings on reused packing material were held not to be clinching proof of origin, particularly when the adjudicating authority itself noted that such markings were insufficient and the laboratory tests were inconclusive. The documents were found to be genuine, the transactions moved through banking channels, and the record did not support selective denial of benefit across similarly placed containers without reason.

Conclusion: The country of origin was held to be Sri Lanka, the charge of misdeclaration failed, and the assessee was held entitled to the concessional benefit.

Ratio Decidendi: Where the designated origin authorities certify the country of origin and the contrary material is inconclusive, markings on packing material and unsubstantiated documentary objections are insufficient to deny a preferential customs benefit.

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