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of HC dismissed the Appellant's challenge and upheld the Tribunal's decision permitting conversion of shipping bills from the MEIS to the DEPB scheme, granting consequential benefits to the Respondent. The Court held that Circular No. 36/2010 permits conversion where documentary evidence contemporaneous with export establishes scheme eligibility; here imported inputs were used in manufacture and export documents satisfied scheme conditions. The revenue's characterization of the shipping bills as 'free' and its attribution of non-examination to the Respondent were found erroneous. The Tribunal correctly treated the conversion as between schemes with comparable examination scales. Substantial questions of law were answered in favor of the Respondent and against the Appellant.
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