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of The SC held that oil contained in bunker tanks, whether inside or outside the engine room of vessels sent for scrapping, must be valued and assessed as part of the ship itself rather than separately. This decision aligns with the precedent established in M/S Mahalaxmi Ship Breaking Corp. v. Commissioner of Customs Bhavnagar, which clarified the valuation approach for such cases. Consequently, the appeal was dismissed in accordance with this binding precedent, confirming that the oil's assessment cannot be segregated from the vessel's overall valuation for customs purposes.
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