Rules-of-origin exemption cannot be denied across consignments merely because one certificate of origin was revoked.

Exemption under a rules-of-origin trade arrangement cannot be denied for multiple consignments merely because one certificate of origin is revoked. The authority must independently verify each consignment and follow the prescribed notice and determination procedure before rejecting origin eligibility or imposing duty, interest, penalty, or confiscation-related consequences. A revocation affecting one certificate does not, by itself, prove that other consignments are ineligible or that their supporting certificates are invalid. On that basis, the adverse order was set aside and the appeal succeeded.

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Issues: Whether denial of exemption and consequential duty, interest, penalty and redemption fine could be sustained merely on the revocation of one certificate of origin, without scrutiny and notice in respect of the individual consignments.

Analysis: The imports were supported by certificates of origin issued by competent authorities under the ASEAN-India Free Trade Agreement framework. The revocation of one certificate, by itself, did not establish that the remaining consignments lacked origin eligibility or that the certificates accompanying them were unauthentic or non-compliant. The relevant rules and operational certification procedures did not permit the revocation to be treated as a substitute for the verification process contemplated under the agreement, and the authority was required to follow the prescribed notice and determination process before denying the exemption. The record did not show a proper consignments-wise verification or a legally sustainable basis for extending the adverse result from one certificate to all imports.

Conclusion: The denial of exemption and the resulting demand, penalties and confiscation-related consequences were not sustainable.

Final Conclusion: The impugned order was set aside and the appeal succeeded.

Ratio Decidendi: An exemption under a rules-of-origin based trade agreement cannot be denied across multiple consignments merely because one certificate of origin is revoked, unless the authority independently verifies the relevant consignments and follows the prescribed statutory and treaty-based procedure.

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