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Belated re-testing of remnant iron ore samples cannot displace contemporaneous representative-sample results without objective, legally sustainable grounds. The notes state that samples analysed at export were corroborated by load-port and discharge-port reports, contractual price adjustments and realised sale proceeds. A re-test conducted more than a year after export was considered unreliable because storage and laboratory drying could affect moisture content and could not recreate the goods' condition at export. The delayed re-test and final assessment based on it were set aside, and the exported iron ore fines qualified for export duty and cess exemption on evidence of iron content below the prescribed threshold.
Belated re-testing of remnant iron ore samples cannot displace contemporaneous representative-sample results without objective, legally sustainable grounds. The notes state that samples analysed at export were corroborated by load-port and discharge-port reports, contractual price adjustments and realised sale proceeds. A re-test conducted more than a year after export was considered unreliable because storage and laboratory drying could affect moisture content and could not recreate the goods' condition at export. The delayed re-test and final assessment based on it were set aside, and the exported iron ore fines qualified for export duty and cess exemption on evidence of iron content below the prescribed threshold.
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