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<h1>Transfer of imported goods: veiled sales through replenishment by merchant exporters negate duty-free advance licence benefits.</h1> Whether goods imported duty free under Notification No. 204/92 by a Merchant Exporter and supplied as replenishment to a supporting manufacturer constitute a transfer is decided by the scheme's intention: licences and imported materials are subject to an actual user condition. Outright purchases embedding input costs amount to a veiled sale and disqualify duty free benefit where Modvat has been availed; job work or contracts limited to jobbing charges that do not transfer ownership satisfy the Notification.