Imposition of penalty on the basis of mathematical variation is unsustainable

Siba International Vs Commissioner of Customs (CESTAT Mumbai) 

Facts of the case, in a nutshell, is that Appellant-Exporter Siba International was engaged in export of processed buffalo meat after procuring the same from M/s. Al-Azlan Frozen Foods, Moradabad (UP) an approved processing plant for export of boneless buffalo meat as a prescribed condition under Chapter 2 of Schedule 2 of the ITC (HS) Classification of Export and Import items requires the exporter to produce certificate

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