Duty drawback depends on notified export goods and relevant duty-paid inputs, not duty on every raw material used.

Drawback on salfat oil was treated as confined to refined salfat oil, and the exporter was permitted to adduce supplementary evidence to prove that the consignments met that description; entitlement was not rejected outright. Rule 3 of the Duty Drawback Rules was held to apply even where duty had been paid only on some inputs, because the scheme does not require duty payment on every raw material used in manufacture. The operative principle is that drawback depends on the notified export item and the duty incidence on relevant inputs, so denial cannot rest solely on the absence of duty on all inputs.

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Issues: (i) Whether drawback on salfat oil was confined to refined salfat oil and whether the claim could be supported by additional evidence. (ii) Whether Rule 3 of the Duty Drawback Rules applied where duty was paid only on some of the inputs used in manufacture.

Issue (i): Whether drawback on salfat oil was confined to refined salfat oil and whether the claim could be supported by additional evidence.

Analysis: The classification history and the subsequent clarification showed that the drawback entry for salfat oil was intended to cover refined salfat oil. Refining was treated as the relevant stage because drawback cannot be granted where no duty-paid material has gone into the manufacture of the exported item. On the facts, the exporter was permitted to produce supplementary evidence to establish that the consignments were of refined salfat oil, with the degree of proof to be assessed consistently with the treatment given to other consignments.

Conclusion: The claim was not rejected outright, and the exporter was allowed to adduce supplementary evidence to establish entitlement to drawback on refined salfat oil.

Issue (ii): Whether Rule 3 of the Duty Drawback Rules applied where duty was paid only on some of the inputs used in manufacture.

Analysis: The rule was held applicable. It was further held that the rule does not require duty to have been paid on every raw material or input used in the manufacture of the final product. Where the final product is notified in the drawback schedule, the scheme must operate having regard to the duty incidence on the relevant inputs, and the existence of some duty-paid inputs is sufficient for the rule to operate.

Conclusion: Rule 3 applied, and drawback could not be denied merely because duty had not been paid on all inputs.

Final Conclusion: The matter was sent back for fresh disposal of the drawback claim in light of the above findings, with consequential relief to follow if entitlement was established.

Ratio Decidendi: A drawback claim depends on the notified export item and the duty incidence on inputs actually relevant to its manufacture, and the absence of duty on every input does not by itself defeat entitlement where the scheme otherwise applies.

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