Invoice-number discrepancies in origin certificates can support customs exemption notices, requiring factual explanation before the competent customs authority.

An apparent mismatch between the invoice number in a certificate of origin and the invoice submitted for import can provide sufficient jurisdictional facts to issue a show-cause notice denying preferential customs-duty exemption. Referral of the certificate for CID investigation does not eliminate that discrepancy. Authorities addressing undisclosed or incomplete overseas enquiries do not apply where the notice identifies the precise factual anomaly on which it relies. The importer's explanation requires factual examination by the competent customs authority in the first instance, rather than pre-notice intervention.

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Issues: Whether the show-cause notice concerning denial of preferential customs-duty exemption could be challenged for want of jurisdictional facts where the certificate of origin contained an apparent invoice-number discrepancy.

Analysis: Verification undertaken under the customs origin-verification framework disclosed that the invoice number in the certificate of origin relied upon by the petitioner differed from the invoice produced for import. Referral of the certificate to the CID for investigation did not remove or negate that apparent discrepancy. The precedents concerning reliance on incomplete and undisclosed overseas enquiries were inapplicable because the notice identified the specific factual anomaly forming its basis. The petitioner's explanation of the discrepancy requires factual consideration by the customs authority in the first instance.

Conclusion: The invoice-number discrepancy constituted sufficient jurisdictional facts for issuance of the show-cause notice; the petitioner must place its explanation before the competent customs authority.

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