Certificate of Origin verification procedures governed preferential customs exemption, rendering denial of treaty benefits and consequential penalty unsustainable.

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....Preferential customs-duty exemption under the Indo-Thailand Free Trade Agreement depends on compliance with the prescribed process for verifying a Certificate of Origin under the Interim Rules of Origin. The text states that Revenue did not follow the procedure in Notification No. 101/2004-Cus. (N.T.) before challenging the certificate's credibility. It therefore records that denial of exemption under Notification No. 85/2004-Cus. was unsustainable, as was the consequential penalty for alleged improper import. The impugned order was set aside and the appeals were allowed with consequential relief.....