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    Duplicate substantive additions cannot survive where seized-ledger amounts were already taxed in the acknowledged owner's hands.
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      Post-export conversion of free shipping bills into EPCG shipping...

      Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and delayed requests.

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      CustomsAugust 19, 2026Case LawsAT
      Post-export conversion of free shipping bills into EPCG shipping bills cannot be rejected solely for delay where contemporaneous documentary evidence supports the export. The three-month limitation prescribed by a Board Circular was treated as inconsistent with Section 149, while the one-year period under the 2022 Regulations applies prospectively and does not govern earlier exports. Failure to state EPCG authorisation details in the original free shipping bills is a curable procedural lapse when export duty payment records, invoices and bank realisation documents establish the goods exported and receipt of export proceeds. Conversion must be processed after verification of that evidence.

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      ActsIncome Tax