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Issues: Whether the application for reduction of re-export fine and personal penalty was liable to be rejected, and whether the order-in-appeal granting relief with a fixed time limit had to be implemented forthwith despite the absence of a review certificate.
Analysis: The appellate authority had consciously granted relief and fixed a time-frame for implementation, which was to be respected and carried out without waiting indefinitely for a possible review. The order could not be indirectly frustrated by withholding implementation on the ground that no review certificate had yet been received. Since no review had been filed and the appellate order appeared prima facie unobjectionable, the proper course was immediate implementation of that order.
Conclusion: The request for reduction of the re-export fine and personal penalty was rejected, and the order-in-appeal was directed to be implemented forthwith.