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Rejection of rebate claim - In the case in hand, it is not in dispute that the goods were exported by sea and the bills of lading are dated 03.06.2004 and 18.06.2004. Hence, any date prior to that cannot be taken as the date of export of goods. - The plea of estoppel is also merely to be noticed and rejected for the reason that there cannot be estoppel against statute. Once Section 11-B of the Act clearly defines when the goods are treated to be exported. - HC