Endorsement copies of ARE-3 cannot be treated as final proof of export

In re M/s Indian Oil Corporation Ltd. (GST AAAR West Bengal) The Appellant has admitted that the NOC issued PDO (Product Delivery Order) on Raxaul Depot of the IOCL which is actually the supply point of the products. And the Appellant’s Raxaul unit prepared and submitted ARE-1 (Application for Export) to the Customs Authority for endorsement. Hence, the final clearance of goods for export has taken place from the Raxaul unit, the export warehouse of the Appellant and not from the Appellant’s Haldia unit. Therefore, endorsement copies of ARE-3 cannot be treated as final proof of exp...