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 from the designated veterinary authority as well as from the quality control and inspection authority, besides ...