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Issues: Whether amendment of the shipping bills to change the scheme code from Drawback to RoSCTL could be permitted after export, and whether the time limit in the circular could bar such amendment.
Analysis: The dispute turned on the scope of amendment under Section 149 of the Customs Act, 1962 and the manner in which the procedural requirement for conversion of shipping bills was to be applied. The Tribunal noted that the respondent's claim was supported by the decisions relied upon and that the subsequent issuance of the Export Entry (Post Export Conversion in relation to Instrument Based Scheme) Regulations, 2025 reinforced the view that the earlier circular-based restriction was not ative of the exporter's entitlement. On the facts, the amendment had been allowed by the adjudicating authority.
Conclusion: The amendment of the shipping bills was held to be permissible and the Revenue's challenge failed.
Final Conclusion: The order allowing conversion of the shipping bills was sustained and the Revenue's appeal was rejected.
Ratio Decidendi: Amendment of shipping bills under Section 149 of the Customs Act, 1962 cannot be denied on a rigid circular-based time limit where the statutory power permits amendment on the basis of existing documentary evidence and the claim is otherwise legally maintainable.