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    <title>2026 (3) TMI 478 - CESTAT CHANDIGARH</title>
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    <description>A CRCL report stating only that imported goods had characteristics consistent with base oil was insufficient to justify reclassification as base oil, rejection of the declared value, and consequential duty and penalty demands. The report did not categorically establish that the goods were base oil, and the denial of cross-examination of the Chemical Examiner further weakened the department&#039;s evidentiary basis by preventing clarification of the report. In the absence of definitive and corroborative evidence, the benefit of doubt went to the importer. On identical facts, the coordinate-bench view, as affirmed in later proceedings, supported the same result, and the revenue&#039;s challenge failed.</description>
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      <description>A CRCL report stating only that imported goods had characteristics consistent with base oil was insufficient to justify reclassification as base oil, rejection of the declared value, and consequential duty and penalty demands. The report did not categorically establish that the goods were base oil, and the denial of cross-examination of the Chemical Examiner further weakened the department&#039;s evidentiary basis by preventing clarification of the report. In the absence of definitive and corroborative evidence, the benefit of doubt went to the importer. On identical facts, the coordinate-bench view, as affirmed in later proceedings, supported the same result, and the revenue&#039;s challenge failed.</description>
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