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Whether a substantial question of law arose regarding assessment of Fe content in exported iron ore fines was resolved by treating the dispute as factual. The tribunals consistent precedent and an SKM certificate testing samples on wet metric tonne basis (WMT) governed the Fe percentage, whereas a CRCL report using dry metric tonne basis (DMT) reflected moisture loss over delayed testing. The determination that Fe content on WMT was below the tariff threshold attracted nil export duty under the applicable notification and the concurrent factual findings of the Appellate Authority and CESTAT were affirmed, leading to dismissal of the revenue appeal.
Whether a substantial question of law arose regarding assessment of Fe content in exported iron ore fines was resolved by treating the dispute as factual. The tribunals consistent precedent and an SKM certificate testing samples on wet metric tonne basis (WMT) governed the Fe percentage, whereas a CRCL report using dry metric tonne basis (DMT) reflected moisture loss over delayed testing. The determination that Fe content on WMT was below the tariff threshold attracted nil export duty under the applicable notification and the concurrent factual findings of the Appellate Authority and CESTAT were affirmed, leading to dismissal of the revenue appeal.
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