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2026 Supreme(Online)(CESTAT) 345

CUSTOMS EXCISE & SERVICE TAX APPELLATE TRIBUNAL
D.M. Misra, J, R. Bhagya Devi, Technical Member
M/s. Patanjali Foods Ltd. – Appellant
Versus
The Commissioner of Customs – Respondent


Advocates:
For the Appellant: Shri Rajesh Rawal
For the Respondent: Shri M. Sreekanth, Asst. Commissioner (AR)

Table of Content
1. overview of appeals and claims for duty exemption. (Para 1 , 2)
2. discussion on test reports and compliance with notification. (Para 3 , 4)
3. examination of facts and legal interpretations regarding exemptions. (Para 5)

PER: R. BHAGYA DEVI

These 2 Appeals Nos. C/20073-20074/2014 have been filed by the appellant M/s. Ruchi Soya Industries Pvt. Ltd (Presently known as M/s. Patanjali Foods Limited) against the impugned Order-in-appeal No.399/2013 dated 25.10.2013 and Order-in-Appeal No. 389/2013 dated 15.10.2013 respectively passed by the Commissioner of Customs (Appeals), Bangalore.

2. The facts are that the appellant imported crude palm oil and claimed the benefit of Notification No.21/2002 Cus. dated 01.03.2002 (Sl.No.30II(A) claiming the crude palm oil to be of edible grade. Since the eligibility of the Notification was in dispute and the imported goods had to be tested, the appellant requested for provisional assessment which was accepted by the Revenue. On finalization of the provisional assessments based on the test reports, the benefit of the Notification was denied and differential duty was demanded by the original authority. On appeal, the Commissioner (Appea

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