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of Valuation of imported goods - difference between value as per proforma Invoice and actual value - no case of any malafide is made out against the appellant. At best, it is the mistake of the authorised courier who was not vigilant at the time of booking of the courier parcel to ensure the correct declaration by the shipper. - No case of any collusion is made out against the appellant shipper and /or against the courier - thus, penalty have been imposed mechanically without proper appreciation of the facts and the law applicable. - AT
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