IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/TAX APPEAL NO. 10 of 2025 =============================================

THE COMMISSIONER OF CUSTOMS Versus CENTURY PLYBOARDS LTD.

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Appearance:

MR DEEPAK N KHANCHANDANI(7781) for the Appellant(s) No. 1 =============================================

CORAM:HONOURABLE MR. JUSTICE A.S. SUPEHIA and HONOURABLE MR. JUSTICE PRANAV TRIVEDI Date : 24/04/2026

ORAL ORDER

(PER : HONOURABLE MR. JUSTICE A.S. SUPEHIA)

1. The following proposed substantial questions of law arise for determination of the present appeal.

“(i) Whether Tribunal is correct in allowing Refund, whereas as per Rule 21 of Customs Tariff (Identification, Assessment And Collection of Anti-Dumping Duty On Dumped Articles And For Determination of Injury) Rules, 1995, there is no provision of Refund in the case of Review of Anti Dumping Duty under Rule 23 ibid?

(ii) Whether Tribunal is correct in allowing Refund, whereas the conditions of Section 9AA of Customs Tariff Act, 1995 and Rule 21 A of Customs Tariff (Identification, Assessment And Collection Of Anti- Dumping Duty on Dumped Articles And For Determination Of Injury)

Rules, 1995 has not been fulf