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    <title>Conversion of shipping bills from drawback to DFIA scheme upheld; three-year limit rejected after appellate direction and res judicata.</title>
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    <description>Refusal to convert shipping bills from drawback to DFIA was held unsustainable because an earlier appellate order had already directed conversion for all remaining shipping bills, causing the Commissioner&#039;s subsequent order allowing conversion for three years to merge with that appellate determination; the Revenue, having participated earlier, was barred from reopening the issue by res judicata. The restriction relied on under Circular No. 36/2010-Cus. was treated as inconsistent with s.149 of the Customs Act as held in prior judicial decisions, supporting validity of conversion. Consequently, conversion for the three-year period was upheld and the Revenue&#039;s appeal was dismissed. -CESTAT</description>
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    <pubDate>Wed, 17 Dec 2025 15:52:20 +0530</pubDate>
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      <title>Conversion of shipping bills from drawback to DFIA scheme upheld; three-year limit rejected after appellate direction and res judicata.</title>
      <link>https://www.taxtmi.com/highlights?id=95116</link>
      <description>Refusal to convert shipping bills from drawback to DFIA was held unsustainable because an earlier appellate order had already directed conversion for all remaining shipping bills, causing the Commissioner&#039;s subsequent order allowing conversion for three years to merge with that appellate determination; the Revenue, having participated earlier, was barred from reopening the issue by res judicata. The restriction relied on under Circular No. 36/2010-Cus. was treated as inconsistent with s.149 of the Customs Act as held in prior judicial decisions, supporting validity of conversion. Consequently, conversion for the three-year period was upheld and the Revenue&#039;s appeal was dismissed. -CESTAT</description>
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      <pubDate>Wed, 17 Dec 2025 15:52:20 +0530</pubDate>
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