JUDGMENT

YASHWANT VARMA, J.

1. The instant writ petition has been preferred for directions being framed commanding the respondents to finalize the provisional assessment in respect of Bill of Entry1 No. 2894698 dated 12 October 2015, as also to release the Bank Guarantee2 dated 13 July 2016 which had been furnished by the petitioner awaiting finalization of the provisional assessment proceedings. For the purposes of considering the prayers as made it would be apposite to notice the following essential facts.

2. The petitioner is stated to be engaged in the business of import and trading of assorted gold jewellery and holds a valid Importer Exporter Code3. On 13 August 2009, the Agreement on Trade in Goods under the Framework Agreement on the Comprehensive Economic Cooperation4 with the Association of Southeast Asian Nations5, including Indonesia was entered into with India granting preferential treatment to goods imported from ASEAN countries. For purposes of implementing the terms of the FTA, the Customs Tariff [Determination of Origin of Goods under Preferential Trade Agreement between the Government of Members States of the Association of South-East Asian Nations (ASEAN) and the Re