Reassessment in Customs Cases Only with Pre-existing Documents at Clearance Time per Section 149; No Penalty Imposed Here.

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....Waiver of Penalty - Section 149 permits reassessment only in the circumstances and on the strength of “documentary evidence which was in existence at the time goods were cleared, deposited or exported”. It is not clear that country of origin certificate were available at the time of clearance of goods - appellants have correctly described the product in the bills of entry and claimed the notification - no penalty....