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    <title>2026 (4) TMI 1845 - CESTAT KOLKATA</title>
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    <description>A valid Certificate of Origin accepted at import and later confirmed by the issuing foreign authority cannot be unilaterally rejected by Customs on domestic verification alone, so preferential SAFTA duty benefit was restored. Selective post-import retesting of only a few samples could not be extended across all consignments to reclassify the goods as low erucic acid rapeseed oil, making the Revenue&#039;s sampling method legally unsound. Where bills of entry, test reports, and origin certificates were disclosed at import and no suppression, wilful misstatement, or collusion was shown, the extended limitation period was unavailable and the demand was time-barred; the duty, interest, and penalties were set aside.</description>
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