https://www.taxtmi.com/caselaws?id=783418 The authority held that preferential duty under APTA is available only where goods qualify as originating in terms of the substantive Rules of Origin under the relevant notification and are supported by a valid Certificate of Origin. As the APTA framework and notified Rules contain no provision permitting third-party invoicing or third-country trade, mere reference to "third-party trade" in procedural notes for completing the Certificate of Origin cannot create a substantive right. Instruction No. 23/2024 likewise cannot expand treaty benefits beyond the text. Consequently, third-party invoicing is not permissible for claiming APTA benefits, and the applicant is not entitled to preferential duty. en-us Thu, 11 Dec 2025 00:00:00 +0530 Fri, 12 Dec 2025 10:48:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783418 The authority held that preferential duty under APTA is available only where goods qualify as originating in terms of the substantive Rules of Origin under the relevant notification and are supported by a valid Certificate of Origin. As the APTA framework and notified Rules contain no provision permitting third-party invoicing or third-country trade, mere reference to "third-party trade" in procedural notes for completing the Certificate of Origin cannot create a substantive right. Instruction No. 23/2024 likewise cannot expand treaty benefits beyond the text. Consequently, third-party invoicing is not permissible for claiming APTA benefits, and the applicant is not entitled to preferential duty. Case-Laws Customs Thu, 11 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783418