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Whether amendment in the Bills of Entry can be allowed even when the Certificate of Origin was issued at a later date retrospectively and was not available at the time of clearance of the Bills of Entry in contravention of the section 149 of the Customs Act 1962? - The stipulation of Section 149 of the Act or any other provisions incorporated under the Act or the Rules for compliance of duty payment may not stand in the way of the assessee to claim exemption under Section 25 of the Act. - HC

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