Per: M.M. PARTHIBAN

This appeal has been filed by M/s Bayer Crop Science Limited, Thane (herein after, referred to as ‘the appellants’, for short), assailing the Orders-in-Original No. 190/2023-24/Commr/NS-II/CAC/JNCH dated 06.12.2023 (herein after, referred to as ‘the impugned orders’), passed by the Commissioner of Customs (NS-II), Jawaharlal Nehru Custom House (JNCH), Nhava Sheva.

2.1 Briefly stated, the facts of the case are that the appellants herein, inter alia, is engaged in manufacture of Agrochemicals, Pesticides, Insecticides and Herbicides, and mainly export insecticides viz. ‘ADMIRE’, ‘DECIS’, ‘SHOONA, ‘SOLFAC’, ‘SOLOMON’ by classifying such goods under Customs Tariff Item (CTI) 3808 91 99 of the Customs Tariff Act , 1975. The appellants are one of the largest and leading research-intensive companies in the agricultural industry, offering a broad range of innovative and biological products for improving plant health, along with high value seeds. The appellants were exporting their manufactured products to various countries by availing export inventive schemes such ‘Merchandise Exports from India Scheme (MEIS) under Chapter 3 of the Foreign Trade Policy 2015-2020.

2.2 The