Certificate of Origin verification safeguards concessional duty benefit when customs doubts origin without following prescribed checks.

Under the India-Singapore preferential trade arrangement, customs could not deny concessional duty merely because the imported goods were said not to correlate perfectly with the Certificate of Origin. The Certificate of Origin, issued by the competent certifying authority, remains valid unless the prescribed verification or retroactive-check procedure is followed where origin is doubted, and minor discrepancies do not by themselves invalidate it. Here, the certificate and supporting documents matched the description, weight, quantity and packing details, and there was no evidence of fraud or forgery. The denial of notification benefit was therefore unjustified, and the importer was entitled to the concession.

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Issues: Whether the customs authorities were justified in denying the concessional duty benefit under the notification on the ground that the imported goods could not be correlated with the Certificate of Origin accompanying them.

Analysis: The exemption notification required the importer to establish Singapore origin in accordance with the Rules of Origin notified for the India-Singapore preferential trade arrangement. The Certificate of Origin is issued by the designated certifying authority after verification, and the operational procedure recognises that minor discrepancies do not ipso facto invalidate the certificate if it corresponds to the goods. Where the customs authorities entertain reasonable doubt, the prescribed course is to seek clarification or a retroactive check from the certifying authority rather than reject the certificate summarily. In the present case, the rejection rested on the absence of marks and numbers on plain bags, although the certificate and supporting documents showed conformity of description, weight, quantity and packing details, and there was no evidence of fraud, forgery, or any attempt to invoke the prescribed verification mechanism.

Conclusion: The denial of the concessional duty benefit was unjustified, and the assessee was entitled to the notification benefit.

Ratio Decidendi: A valid Certificate of Origin issued by the competent certifying authority cannot be disregarded on a summary assumption of deficiency; if origin is doubted, the customs authorities must follow the verification and retroactive-check procedure prescribed in the applicable Rules of Origin.

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