Certificate of origin defects were treated as curable, preserving customs exemption where the document matched the imported goods.

A certificate of origin may not be rejected for mere minor discrepancies where it otherwise corresponds to the imported goods and the defect is duly rectified under the governing rules. Applying Rule 18, the corrected certificate, supported by the exporter's declaration and the required seals and signatures, was treated as curing the earlier defect. On that basis, rejection of the certificate was unsustainable and the importer remained entitled to exemption or concessional tariff under Notification No. 96/2008-Cus., so the duty demand based on that rejection did not survive.

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Issues: Whether a certificate of origin could be rejected for minor discrepancies and whether the importer remained entitled to exemption under the relevant customs notification.

Analysis: The discrepancy in the original certificate of origin was treated as a minor defect, not a substantive invalidity. The later corrected certificate, bearing the exporter's declaration as well as the seals and signatures of the exporter and competent authority, was held to cure the defect. Rule 18 of the rules governing certificates of origin was applied to hold that minor discrepancies between the certificate and import documents do not ipso facto invalidate the certificate, provided it corresponds to the imported goods.

Conclusion: The rejection of the certificate of origin was unsustainable and the importer was entitled to the benefit of exemption or concessional tariff under Notification No. 96/2008-Cus.

Final Conclusion: The duty demand based on rejection of the origin certificate did not survive, and the appeal was allowed with consequential relief.

Ratio Decidendi: A certificate of origin cannot be invalidated merely for minor discrepancies if the document otherwise corresponds to the goods imported and the defect is duly rectified in accordance with the governing rules.

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