TaxTMI 
TaxTMI 
2024 (3) TMI 869
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.... shipments valued at approximately Rs. 27 Crores have been imported from diverse suppliers from countries like Japan, China etc. stretched over a period of nearly five years where the suppliers described the imported goods as fish protein. Accordingly, show-cause notice was issued to the appellant for mis-declaring the goods. Based on the test reports, various documents found during investigation and based on various statements, the Commissioner in the impugned order classified the products under chapter heading 0511 9190 and demanded the differential duty. Since most of them were cleared under Advance Authorisation Scheme declaring them as 'fish protein', the benefit of Notification No. 96/2009 dated 11.09.2009 was denied. On account of suppression of the correct description of the goods and for mis-declaring the same, the goods were confiscated and allowed to be redeemed on payment of redemption fine. Penalties were imposed under Section 112(a), 114A and 114AA of the Customs act 1962. 2. The Learned Sr. counsel on behalf of the appellant placed on record technical literature, various test reports, documents and the statements to submit that the goods were rightly classifiable un....
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....sh is easier to digest and absorb than that of terrestrial origin, due to the different hydroxyproline contents and a lower denaturation temperature. However, the information reported on the characteristics and methods of extracting collagen is still not enough. Tilapia (Oreochromis aureus) is one of the main groups of fish grown and sold as whole frozen fish and frozen and fresh fillet. Tilapia skin is a byproduct that contains about 27.8% collagen ad can be used for the extraction of collagen increasing the economic value of these industries. It has been reported that collagen is composed of glycine (33%), proline (12%), alanine (11%), and hydroxyproline (10%) but is deficient in essential amino acids such as lysine and tryptophan. The methodology for the extraction of collagen includes steps such as pretreatment of the raw material and isolation of collagen. The fish products as collagen sources need a previous cleaning and size reduction, in order to facilitate the elimination of impurities and ensure the maximum collagen extraction. In addition, it is important to classify the waste generated by industrial processing such as the skin, scales, fins, and bones since they have ....
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....lution at pH 7.4. The demineralized fish scale was washed thrice with distilled water and used further. Demineralized fish scale was analyzed by thermogravimetry (TGA) to confirm the complete dissolution of calcium phosphate." D) It is further claimed that prior to June 2010, they produced peptide from Bovine Bone Protein and later proposed to manufacture Peptide using an alternate starting material, namely Fish Protein. Before a new line of activity is commenced, external expert opinion is obtained about compliance with various laws including import/custom laws. Accordingly, the Appellant vide letter dated 31.05.2010 together with a technical write-up of the proposed imported product, sought the opinion of Foreign Trade consultants, namely Trade Track, Cochin. In that letter dated 31.5.2010, Appellant inter alia, queried the expert about applicability of Heading 05.04 or Heading 35.04 of Customs Tariff Act, 1975 to the imported goods. The said Consultants opined that imported Protein made from Fish Scale would fall under Tariff Item 3504 0099. In April 2016, supplier PT Fortune Star from a new country Indonesia, was identified by them and the same goods were being imported from ....
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.... description as fish protein by these suppliers is at the prompting of the appellant. This also establishes that goods in question are commercially bought and sold internationally as fish protein only. Since imported goods in question are essentially protein, and the source of the protein is fish, Appellant imported the goods, under the nomenclature Fish Protein. The terms like milk protein, soya protein etc. indicate the source of the protein. Similarly, Fish Protein indicates that the source of the protein is fish. If the imported product is to be described by the process employed by overseas supplier to obtain it, it could be equally described as decalcified fish scale or more accurately, demineralized fish scale. It is therefore obvious that the expressions "fish protein" and "decalcified fish scale" are synonyms terms and are not mutually exclusive or contradictory terms. A consignment of fish protein was imported by Appellant vide Bill of Entry No. 7867111 dated 06.09.2012 of China Origin where it was classified under Tariff Item 3504 0090. Along with the Bill of Entry, they filed Health Certificates issued by the regulatory authority of the exporting country and the Health C....
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....OAC 2012 ppm 602.7 7. Potassium AOAC 2012 ppm 28.82 Sl. No. Test Test Method Unit Results obtained *Amino acid 1. Aspartic acid J. Chromatography 204:143-148 g/100g 6.89 2. Threonine J. Chromatography 204:143-148 g/100g 2.75 3. Serine J. Chromatography 204:143-148 g/100g 3.46 4. Glutamic acid J. Chromatography 204:143-148 g/100g 10.82 5. Proline J. Chromatography 204:143-148 g/100g 11.99 6. Glycine J. Chromatography 204:143-148 g/100g 24.19 7. Alanine J. Chromatography 204:143-148 g/100g 10.17 8. Cysteine J. Chromatography 204:143-148 g/100g 0.00 9. Valine J. Chromatography 204:143-148 g/100g 2.76 10. Methionine J. Chromatography 204:143-148 g/100g 1.19 11. Isoleucine J. Chromatography 204:143-148 g/100g 1.54 12. Leucine J. Chromatography 204:143-148 g/100g 3.42 13. Tyrosine J. Chromatography 204:143-148 g/100g 5.36 14. Phenyl alanine J. Chromatography 204:143-148 g/100g 1.69 15. Histidine J. Chromatography 204:143-148 g/100g 2.23 16. Lysine J. Chromatography 204:143-148 g/100g 5.75 17 Arginine J. Chromatography 204:143-148 g/100g 7.32 Central ....
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....e departments query vide letter dated 7.10.2016 where SIIB had specifically asked for a generalized write-up, post their test report, CIFT vide letter dated 14.10.2016 reported as under: J) Thus, prompted by the above-referred repeated letters of the Department, as to whether the imported goods are processed Fish Scale, CIFT/CMFRI, inter alia, indicated that the tested samples are processed fish scales obtained by demineralization. These letters/tests reports have to be understood in their context and nowhere directly or indirectly, expressly or by implication, suggest the imported goods are not Fish Protein. The imported decalcified fish scale/fish protein is treated with dilute sulphuric acid in their factory which helps precipitating non-collagen proteins present in imported decalcified fish scale/fish protein. Balance/remainder is collagen protein. The Appellant thereafter undertakes enzymatic reaction to break longer chain protein into shorter chain peptide by hydrolyzing with hot water. Thus, collagen peptide is obtained from imported starting material Fish Protein/decalcified fish scale. In view of the above it is submitted that the SCN and Impugned order suggests that the....
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....orm ash (inorganic). Accordingly, the classification under Heading 35.04 cannot be rejected on account of existence of traces of impurities, particularly in the absence of any section note or chapter note stipulating purity criteria in this Heading 35.04. Further, Ld. Commissioner also observed that that for getting protein, there has to be some process like extraction and purification. According to impugned order, the unwanted material (namely calcium and other minerals) alone are being separated by overseas supplier and no extraction is involved to obtain the protein. Therefore, the imported goods are not classifiable under Heading 3504. The above observation of Ld. Commissioner are not valid or correct. Heading 3504 does not stipulate that protein must be 'extracted' in order to fall under the same. There is no reference to extract or extraction in Heading 35.04. it is claimed that many proteins falling under specific Heading 3501, 3502, 3503 and other protein falling Heading 3504 are also obtained by the process of separation and not only by extraction. As per the Ld. Commissioner, the imported goods are classifiable under Heading 0511 only on account of the fact that the impug....
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....siduary heading and therefore not to be preferred. L) Imports of Fish Protein other than under Advance Authorizations were always cleared by Appellant on payment of duty under Tariff Item 35040090. Also, in instances where final product was not exported though imports were against advance authorizations, Appellant have paid Suo-moto from time-to-time duty otherwise applicable under Tariff Item 35040090. Customs duty under Tariff Item 05119190 was always lower than the Customs Duty under Tariff Item 35040090. Hence, in cases where goods were not cleared against Advance Authorizations, but on payment of duty, no differential duty of Customs is demanded in the SCN or the order. Thus, the entire demand of duty involved in the present case has been only on goods imported against Advance Authorization and not on any other import. M) The learned Counsel further submits that pending investigation, SIIB informed DGFT not to grant 'Export Obligation Discharge Certificate' and not to issue further Advance Authorization to the Appellant. Hence, during the period from April 2016 to September 2019, duty was paid under protest even for imports against Advance Authorization. After the issuance....
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....s decalcified fish scale and hence, Condition (iii) of Notification is fulfilled and therefore duty demand is not maintainable. All applications of Advance Authorization License has been accompanied by technical write up about the process undertaken abroad before goods are imported as also the process to be undertaken in India after imports Advance authorization has been issued accordingly. Whether the goods are Decalcified Fish Scale or Fish Protein as claimed by Customs or Appellant respectively, or whether it falls under Heading 05.11 or Heading 35.04 as claimed by Customs or Appellant respectively, one thing is certain and clear. In view of technical write up filed with the application for advance authorizations, the goods actually imported are the very goods mentioned in the application, based on which advance authorizations have been issued by the licensing authority to the Appellant. There is no doubt that the imported goods fully satisfy this technical write-up with reference to which advance authorization has been issued. Thus, there can be no doubt that goods imported are the very goods referred to in application of appellant for grant of advance authorization. Thus, dema....
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....pig, sheep, goat, fish and fish products; This entry refers to animal and fish feed containing fish and fish products. This entry does not apply to fish product itself is imported. The above is further fortified by the subsequent amendment. Notification S.O. 3112 (E) dated 30.09.2016 amended Notification S.O 2666 I dated 16.10.2014. By the said amended notification dated 30.9.2016, scope of entry No. (vii) of Notification dated 16.10.2014 was expanded. The un-amended and amended entry reads as follows "Unamended entry-(vii) Eggs and seeds of all aquatic animals including fish, crustaceans and molluscs;" Amended entry-(vii) Eggs, seeds and products of all aquatic animals including fish, crustaceans and molluscs; O) Only after amendment made by notification dated 30.09.2016, products of Fish products were covered by general licensing Note 7(B). Thus, there has been no violation of restrictions imposed under the Foreign Trade Policy and therefore Section 111(d) is not invokable. Since the goods are not liable for confiscation under Section 111(d) the Act, there is no liability to penalty under Section 112 (a). Goods covered by Tariff Item 05119190 of ITC (HS) restricted for im....
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....nce Authorization/DFIA. Pursuant to the objection of Department, the Appellant applied for Sanitary Import Permit which was granted without any doubt or objection vide permit dated 4.8.2016 and 7.12.2016 and permit dated 26.7.2018. This establishes that, even in the past i.e. during the period involved in the present case appellant has always been fulfilling the purpose behind the stipulation to obtain Sanitary Import Permit. Hence, the objection of the customs is purely procedural not warranting any penalty since breach if any, in the past is not contrary to the object behind the restriction imposed by ITC(HS). Description of imported goods as fish protein is a correct and valid one, even if the goods are also equally covered by the expression "decalcified fish scale". Hence, there was no mis-description of the goods. Therefore, Section 111(m) is not attracted and no penalty is attracted under Section 112(a) of the Customs Act 1962. consequent to denial of exemption under Notification 96/2009 for imports under advance authorizations, goods imported under said advance authorizations and Notification are confiscated which is incorrect because Section 111(o) applies only when goo....
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.... it tested from CIFT and CIFT vide report dated 20.9.2012 confirmed goods as fish protein. Thereafter, the goods assessed under Heading 35.04 and released for home consumption. Letter dated 14.7.2016 of Superintendent of Group VII of CIFT confirms that CIFT, in their report on the sample drawn by group even as late 2016, has reported goods to be Fish Protein. The duty demand in the present case is only on goods imported under advance authorization. If appellant has applied for import as decalcified fish scale and/or heading 05.11, the advance authorization would have been issued to them and customs could not have any grievance therein. In fact, post impugned order, advance authorization have been indeed so granted by licensing authority. Hence, there is no need or incentive to resort to collusion or mis-statement or suppression of facts. The following observations of Gujarat High Court in L&T Hydrocarbon Engineering Limited vs. Union of India (special civil application no. 1120 of 2019 (decided on 03.02.2022) vide para 100 which is produced below - "100. We may also refer to a decision of the CESTAT in the Geep Industrial Syndicate Ltd. vs. CCE - 1999 (114) ELT 850. In the said ....
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....olumn in the Bill of Entry which can be modified by the officer through re-assessment under section 17 is self-assessment by the importer. Whatever cannot be modified by the officer is a declaration by the importer under Section 46. The self-assessment is the importer's opinion which is subject to re-assessment by the officer and further subject to appeals. The declaration by the importer in the Bill of Entry are factual aspects which must be correctly declared and failure to do so entails action under the Act and the officer cannot modify the importer's declaration. Wrong self-assessment is not mis-declaration by the importer. Similarly, the officer is not liable if his re-assessment gets overturned on appeal nor is the appellate authority liable if his order gets overturned on further appeal." In Midas Fetchem (P) Ltd. and Othrs Vs. Principal Commissioner - 2023 1 TMI 998 CESTAT New Delhi it was held as under: "50. In practice, the importer makes an entry under section 46 and also self-assesses duty under section 17(1) by filing the Bill of Entry. There is no separate mechanism to self-assess duty. The columns pertaining to classification, valuation, rate of duty and e....
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.... the order that the larger period of limitation available under the proviso to Section 28 is not invocable in the present case as there was no deliberate suppression or misstatement. He has therefore confined the demand for a period of the normal period of limitation. He has however applied two years to be the normal period of limitation and, since the show cause notice was issued on 8-11-2014, all imports made after 8-11-2014 have been held to be falling within the normal period of limitation. The appellant has contested this approach by pointing out that demands for the period from 8-11-2014 till 13-5-2016 was time-barred and therefore could not have been the subject matter of the recovery proceedings. It was pointed out that the normal period of limitation was enhanced from one year to two years with effect from 14-5-2016. This was done by an amendment made to the Customs Act by Finance Act, 2016. The position thus was that as on 13-5-2016 i.e. prior to the Finance Act, 2016 coming into force, demand for the period prior to 13-5-2015 had already become barred by limitation. This amendment made was not professedly a retrospective one and thus demands which had already become barr....
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....ad only sub-headings Tariff 35040000. Communications exchanged highlighted these aspects. Request to the supplier to stick to the description of fish protein in invoice, packing list etc. is necessary. In documentary credits like letter of credit, there should be no discrepancy in the description in the documents. Otherwise, banks can dishonour the letters of credit issued by them. Similar difficulty can arise with insurance agencies also. Even for this consignment, country of origin certificate and marking on label described the goods as "decalcified fish scale (fish protein)". It is stated that technical write up was duly filed with customs and they have purchased these very goods under this description for nearly 5 years from various suppliers in countries like China, Japan, for nearly 58 consignments valued at more than Rs. 27 Crores. The communication to indicate description as "fish protein" is no way mis-statement or suppression. 3. The learned Senior Counsel for the Revenue submitted that investigations conducted with 3 live consignments revealed that the impugned goods were 'demineralised fish scale' and not 'fish protein' as described in the bills of entry by the appella....
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....do not satisfy this criterion. The analogy of keratins is not relevant; further, classification of any product should be done in terms of the general interpretative rules and not by citing analogies. iv) The expression 'fish protein' is of the generic nature. It is commonly used to denote protein extracted or obtained from fish sources, as different from protein derived from sources like milk, plants and animals. The appellant had misleadingly described the impugned goods as fish protein even though they had clear knowledge that the impugned goods were only fish scales, which are actually waste products subject to decalcification. Therefore, the impugned goods is only a source of protein and not protein perse. Hence classification of the impugned goods under chapter heading 3504 is ruled out. v) The appellant has relied upon three test reports of CIFT to justify the description indicated by them in the bills of entry. These test reports provide a list of amino acids present in the sample. Based on the same CIFT has opined, after comparing with the animal protein, the sample is fish protein. What has been indicated is that the amino acids present in the subject samples were prot....
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....the goods are in the form of fish scales and by no stretch of imagination they can be regarded as protein substances. Rule 4 of the General Interpretative Rules the kinship Rule would alone apply and the classification of the impugned goods being akin to the fish is rightly classifiable under chapter heading 0511. II) Whether there was a deliberate default on the part of the appellant describing the subject goods in the relevant bills of entry. Referring to the observations of the Commissioner at paragraph 50 of the impugned order it is submitted that the officers of the appellant were aware that the impugned goods were not protein perse and Collagen had to be extracted from the impugned products. The mention of the product description as 'decalcified fiscal for collagen' in the purchase order, the email conversations, the statements of the officials, and the markings of the documents and packages clearly indicate that the officials knew that the products were decalcified for scales and not fish protein to be classifiable under heading 3504. In spite of that the impugned goods were classified as fish protein to claim the benefit of advance authorisation scheme read with the notif....
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....scription is demineralised fish scales allowed to be classified under chapter heading 3504 0099 as claimed by the appellant. (iii) Whether the appellant had mis-declared the description of the product in order to claim the benefit of advance authorization. (iv) Whether the appellant had made any willful mis-declaration of the description of the goods which attracted invocation of extended period under the provisions of the Customs act 1962 which warranted imposition of various penalties. 5. The first is regarding the classification of the imported goods by the appellant. Let's examine the test reports and the technical literature placed before us to understand the nature of the product. The goods imported vide bill of entry No. 5034927 dated 25.04.2016 it was found that the imported products were found in poly propylene bags having marks as "Decalcified fish scale for collagen (fish protein)", HSN code 35040000. Since it was found that the Chapter heading declared by the appellant was incorrect, samples were drawn and sent for testing. The Central Institute of Fisheries Technology (ICAR) Willingdon Island and the Head of Marine Biotechnology Division, Central Marine Fisheries ....
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....ch provides the most specific description shall be preferred to headings providing a more general description. Rule 4. Goods which cannot be classified in accordance with the above rules shall be classified under the heading appropriate to the goods to which they are most akin. 6. For legal purposes, the classification of goods in the sub headings of a heading shall be determined according to the terms of those sub headings and any related sub headings notes and, mutatis mutandis, to the above rules, on the understanding that only sub headings at the same level are comparable. Chapter 5 : Products of animal origin, not elsewhere specified or included (1) (2) (3) (4) (5) (6) 0511 Animal Products Not Elsewhere Specified Or Included; Dead Animals Of Chapter 1 Or 3, Unfit For Human Consumption 0511 10 00 -- Bovine semen Other: kg. 30% - 0511 91 -- Products of fish or crustaceans, molluscs or other aquatic invertebrates; dead animals of Chapter 3 : kg. 0511 91 10 --- Fish nails kg. 30% - 0511 91 20 --- Fish tails kg. 30% - 0511 91 30 --- Other fish waste kg. 30% - 0511 91 90 --- Other kg. 30% ....
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....r 35. The fish waste which is rich source of protein is specifically covered under CTH 0511 (highlighted) and the explanatory notes also clearly mentions that this CTH includes fish waste. It is an admitted fact that the appellant manufactured peptide by using the fish protein contained in the demineralized fish scales imported by them, just because it contains protein which has been extracted through various processes to manufacture peptide the final product it does not make the imported product 'demineralized fish scale'' a 'fish protein'. It is an admitted fact peptide is the product exported by them which is manufactured by using the collagen protein that contained in the demineralized fish scale imported by the appellant. The above facts very clearly depicted in their own technical write-up and process of manufacture (reproduced below) placed before the authorities concerned and it proves that it is fish scale. As has been stated by the Learned Senior Counsel for the revenue, Rule 4 of General Rules of Interpretation the goods are more akin to CTH 0511 and nowhere can be classified under CTH 3504. All the technical literature placed on record only suggests that the impugned p....
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....velopments of contemporary times rather than being held entirely inapplicable. It is for precisely this reason that this Court has repeatedly applied the "common parlance test" every time parties have attempted to differentiate their products on the basis of subtle and finer characteristics; it has tried understanding a good in the way in which it is understood in common parlance." 9. In the present case, the test reports and the technical literature clearly establish that the product imported is demineralised fish scale. As observed by the apex court in the above case the content of protein cannot establish the product as a protein instead it is only a source of protein. More over there is a specific entry for fish waste and it is a settled issued that specific entry will be preferred over other entries and the chapter notes, headings and the explanatory notes clearly establish the product is rightly classifiable under Chapter 5. In view of the above, the products imported by the appellant are rightly classifiable under Chapter Heading 0511 9090. As rightly stated by the Learned Senior Counsel for the Revenue in physical appearance and smell, the goods were nothing but fish scal....
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....d in the authorisation and the value and quantity thereof are within the limits specified in the said authorisation; (iv) that in respect of imports made before the discharge of export obligation, the importer at the time of clearance of the imported materials executes a bond with such surety or security and in such form and for such sum as may be specified by the Deputy Commissioner of Customs or Assistant Commissioner of Customs, as the case may be, binding himself to pay on demand an amount equal to the duty leviable, but for the exemption contained herein, on the imported materials in respect of which the conditions specified in this notification are not complied with, together with interest at the rate of fifteen percent per annum from the date of clearance of the said materials; (v) that in respect of imports made after the discharge of export obligation, if facility of CENVAT Credit under CENVAT Credit Rules, 2004 has been availed, then the importer shall, at the time of clearance of the imported materials furnish a bond to the Deputy Commissioner of Customs or Assistant Commissioner of Customs, as the case may be, binding himself, to use the imported materials in his fa....
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....arge of export obligation to the satisfaction of the Deputy Commissioner of Customs or Assistant Commissioner of Customs, as the case may be, within a period of sixty days of the expiry of period allowed for fulfilment of export obligation, or within such extended period as the said Deputy Commissioner of Customs or Assistant Commissioner of Customs, as the case may be, may allow; (x) that the said authorisation shall not be transferred and the said materials shall not be transferred or sold: Provided that the said materials may be transferred to a job worker for processing subject to complying with the conditions specified in the relevant Central Excise notifications permitting transfer of materials for job work: Provided further that, no such transfer for purposes of job work shall be effected to the units located in areas eligible for area based exemptions from the levy of excise duty in terms of notification Nos. 49/03-C.E. and 50/03-C.E. both dated 10th June, 2003, 32/99-C.E., dated 8th July, 1999, 33/99-C.E., dated 8th July, 1999, 8/04-C.E., dated 21st January, 2004, 20/07-C.E. dated 25th April, 2007, 56/02-C.E., dated 14th November, 2002, 57/02-C.E. dated 14th November....
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....ltant product; (b) mandatory spares within a value limit of ten per cent. of the value of the licence which are required to be exported along with the resultant product; (c) fuel required for manufacture of resultant product; (d) packaging materials required for packing of resultant product; (vi) "Specified Chartered Accountant" means a statutory auditor or a Chartered Accountant who certifies the importer's financial records under the Companies Act, 1956 (1 of 1956) or the Sales Tax/Value Added Tax Act of the State Government or the Income Tax Act, 1961 (43 of 1961). 11. Notification No. 96/2009-Cus dated 11.09.2009 grants exemption to materials imported into India against Advance Authorization in terms of Para 4.1.3 of the Foreign Trade Policy and Para 4.1.3 reads as: Importability/Exportability of items that are Prohibited/Restricted/STE (a) No export or import of an item shall be allowed under Advance Authorization/DFIA if the item is prohibited for exports or imports respectively. (b) Import of restricted items shall be allowed under Advance Authorization/DFIA. 12. The issue revolves around import of fish scales/fish protein imported by the appellant by filing ....
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....classification is concerned. The earlier test reports cannot be brushed aside for the reasons stated by the Commissioner in the impugned order. Therefore, the question of disallowing the benefit of advance authorisation scheme during this period is not sustainable in as much as the goods were declared as fish protein and item was cleared as fish protein as per the advance authorisation scheme. Moreover, these imported goods were actually used in the manufacture of export goods and exported as per the notification 96/2009 is also not under dispute. The fact remains that all the conditions of the notification were satisfied and accordingly all the bills of entry serial number 1 to 42 are to be allowed as per the advance authorisation scheme since the above test reports holds good for all imports made during this period where no fresh samples were drawn or tested. The CESTAT, South Zonal Bench, Bangalore in the case of Magus Metals (P) Ltd. Versus Commissioner of Cus., Hyderabad/Chenna-I vide Final Order Nos. 521-529/2005, dated 4-4-2005 as reported at 2005 (187) E.L.T. 73 (Tri. - Bang.) observed that: "5. We have gone through the rival contentions. The first show cause notice was i....
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....signments dated 24-12-2001 and 24-1-2002, the Revenue was already in the know of the relevant facts, it is difficult to understand as to how the Revenue could have the benefit of anything but the "normal" period of limitation to issue the show cause notices dated 18-3-2003. The order of the learned Tribunal insofar as the six appeals are concerned, holding show cause notices issued therein to be time barred and interfering with the adjudication orders dated 29-3-2004 and 23-9-2004, therefore, must have the approval of this Court." 15. In view of the above observations of the Supreme Court the question of denying the benefit of the advance authorisation scheme to the earlier consignments based on the current test reports of the samples drawn from the 2016 consignments cannot be held against the appellant by invoking suppression. 16. At a later date after physically examining the goods imported vide Bill of Entry No. 5034927 dated 25.04.2016 and 5059997 dated 27.04.2016, samples were drawn noting that goods were packed in white propylene bags and that each bag contained paper label having description 'Declassified fish scale for collagen (Fish Protein)', in the goods had fishy orde....