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Issues: Whether the petitioner was entitled to relief in writ jurisdiction against the concurrent finding that the goods were not proved to have been exported so as to attract exemption from duty under Item No. 22A of the First Schedule to the Central Excises and Salt Act, 1944.
Analysis: The authorities below had concurrently found that the petitioner failed to produce the necessary documentary proof, including the requisite endorsed A.R.4, to show that the goods had in fact been exported. The entitlement to the duty benefit depended upon the Collector being satisfied that the export had actually taken place. On those facts, the question was one of factual satisfaction based on evidence, and the writ court would not ordinarily reassess such concurrent findings or substitute its own view on whether the goods were exported.
Conclusion: The petitioner was not entitled to relief, and the finding that export was not proved stood undisturbed.
Ratio Decidendi: Where entitlement to duty relief depends on proof of actual export and the competent authorities record concurrent findings that the necessary documentary proof has not been produced, the High Court will not interfere in writ jurisdiction with that factual determination.