Conversion of Shipping Bills Allowed Without Time Limit u/s 149 of Customs Act 1962, Overriding CBEC Circular.

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....Conversion of shipping bills from duty drawback scheme to advanced authorisation scheme - mistake in the shipping bills occurred - time limitation - The provision of Section 149 of the Customs Act, 1962 or the rules or notifications made thereunder does not provide any time limit for amendment or conversion of the documents and it is only through the circular issued by CBEC a period of three months have been prescribed. It has been consistently held by the Tribunal that the time limit prescribed by the CBEC is not binding on the court if the Circular is contrary to the statutory provision, then the statutory provision would prevail. - AT....