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    <title>2026 (2) TMI 39 - CESTAT NEW DELHI</title>
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    <description>Eligibility for preferential customs exemption on imported tin ingots depended on compliance with the Rules of Origin under Notification No. 189/2009, including the regional value content and change in tariff sub-heading requirements, supported by a Certificate of Origin issued by the designated authority. The record did not establish that the Certificate of Origin was fake or that the regional value content fell below the prescribed threshold, and the evidence did not reliably dislodge the claimed Malaysian origin with partial manufacture there. On those facts, the conditions for preferential treatment were not shown to have been breached, and the importer was found entitled to exemption under Notification No. 46/2011; the differential customs duty demand was therefore wrongly raised.</description>
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      <link>https://www.taxtmi.com/caselaws?id=785844</link>
      <description>Eligibility for preferential customs exemption on imported tin ingots depended on compliance with the Rules of Origin under Notification No. 189/2009, including the regional value content and change in tariff sub-heading requirements, supported by a Certificate of Origin issued by the designated authority. The record did not establish that the Certificate of Origin was fake or that the regional value content fell below the prescribed threshold, and the evidence did not reliably dislodge the claimed Malaysian origin with partial manufacture there. On those facts, the conditions for preferential treatment were not shown to have been breached, and the importer was found entitled to exemption under Notification No. 46/2011; the differential customs duty demand was therefore wrongly raised.</description>
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