( 1 ) M/s. Rane Diffusion Pvt. Ltd. is a Company, engaged in the manufacture and sale of garments. Shri Arun Kakkar is the Managing Director of the Company. On 5-4-1982, the Government of India issued a notification under S. 25 (1) of the Customs Act, 1962 whereby the goods specified in the Ist Schedule thereto and imported against an Advance Licence issued under the Imports (Control) Orders, 1955, were exempted from customs duty and the whole of the additional duty, leviable thereon under the Customs Tariff Act, 1975, provided : -

(I) the materials in question are required to be imported for the purpose of manufacture of goods for execution of one or more export orders, or (ii) the materials which are for replenishment of materials used in manufacture of goods exported in execution of one or more export orders. The said notification also laid down certain conditions, for claiming exemption.

( 2 ) IN pursuance to this scheme the petitioner secured the requisite Advance licences, and importing 100% polyester fabrics, as well as foreign made zips with the said materials, the petitioner manufactured the garments for export. On 11-6-1986, a shipping bill No. 562 was filed by the company

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