Judicial review of customs show-cause notices may be invoked...

Judicial review of customs show-cause notices may be invoked where jurisdictional facts are absent, including where a notice relies on undisclosed or inconclusive overseas enquiry material. The discussion distinguishes that situation from notices supported by identifiable discrepancies in certificates of origin. A certificate not issued by the stated authority, or an unreconciled mismatch between the certificate's invoice number and the importer's invoice, can provide a factual basis for customs proceedings. Referral of a certificate for further investigation does not itself cure an apparent discrepancy. The importer's explanation is to be examined by the competent customs authority during adjudication.