JUDGMENT :

SONIA GOKANI, J.

1. The petitioner is a Private Limited Company and is engaged in decor paper printing and uses uncoated printing paper, decor paper, base paper and decor base paper as raw material for the purpose of final printing. It purchases the raw material domestically as well as imports the raw material from companies in China.

2. The Petitioner, in the past, has imported the raw materials from Xianhe Company Limited (hereinafter referred to as "Xianhe") and Zhejiang Xianhe New Material Sales Company Limited (hereinafter referred to as "Zhejiang"). The Petitioner since December, 2019 has been importing the raw material from Kingdecor (Zhejiang) Company Limited (hereinafter referred to as "Kingdecor") which is a joint venture company between Xianhe, and Schattdecor, a Chinese and a German Company respectively. The Kingdecor has two related companies Xianhe and Zhejiang in China.

2.1. The Kingdecor supplies the raw material in India through two agencies; M/s. Saraf Sales Corporation and Shah International. The petitioner imported the raw material from the Kingdecor