JUDGMENT

The petitioner is a partnership firm and is engaged in the business of processing and exporting spices and food products. As part of the business activities of the petitioner, the petitioner had exported 20 pallets of Curcumin, packed in 260 HDPE drums, to JSA International, USA on 13.07.2025 as evidenced by Ext.P9. During the time when the aforesaid goods were in transit, a policy decision was taken by the US Government to increase the tariff on export of Indian goods upto 50%. Consequently, the JSA International, USA refused to accept the said consignment, and accordingly, the petitioner was constrained to re-import the said consignment. Ext.P10 is the bill of lading dated 14.11.2025 and Ext.P11 is the Check List- Bill of Entry for Home Consumption submitted by the clearing agency. Ext.P12 is the Bill of Entry dated 29/12/2025. According to the petitioner, in Ext.P12, the total IGST imposed is Rs. 1,03,46,656/-, which, according to the petitioner was not justifiable in view of the fa