RAWAT OIL AND GHEE MILLS (PVT.) LTD. vs FEDERATION OF PAKISTAN through Secretary (Revenue)/Chairman FBR Ss

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RAWAT OIL AND GHEE MILLS (PVT.) LTD. VS FEDERATION OF PAKISTAN through Secretary (Revenue)/Chairman FBR Ss. 25a & 25D---Revision of value determined sought---Subsequent Value Ruling, issuance of---applicability---Importer not being part of revision proceedings---Petitioner/ Importer sought re-assessment of the into-bonded consignments of the petitioner and subsequent release of the same---Consignment of the petitioner was assessed vide assessment Order dated 16.05.2025 under Valuation Ruling No. 1948/2025 dated 06.01.2025 while the noted Valuation Ruling (1948/2025), being the subject matter of Revision Petitions' preferred by various importers, excluding the petitioner, under S. 25D of the Customs act 1969 (' the act 1969') before the Directorate of Customs Valuation subsequently came before the Customs appellate Tribunal ('Tribunal') and ultimately, a fresh Valuation Ruling No.2008/2005 dated 14.07.2025 was issued, categorically revising the earlier / noted Valuation Ruling (1948/2025)---argument of the department / respondent was that the applicability of the Valuation Rulings was only to the Importers seeking revision---Validity---In the present case, the goods were still lying in the bonded warehouse---The Valuation Rulings were statutory rulings and have the force of law, as once the Director General (Valuation) issues a ruling the same has to be duly notified, under the Customs General Orders, 2002---Thus, the arguments of the Respondent were misconceived in respect of the applicability of the Valuation Rulings only to the Importers seeking revision---Notified ruling under S. 25-a of the act 1969 is applicable and binding until revised or rescinded by the competent authority---Once revised, the ruling takes effect from the date when the original/earlier ruling was given, otherwise the same will result in applying a ruling to the importer which is no longer in the field or which the department itself found to be erroneous---Therefore, the petitioner was entitled to the benefit of the revised ruling---Even otherwise, the benefit of any ambiguity or error, relating to the status or the interpretation of a ruling must go to the importer/taxpayer---High Court directed the respondents /Department to re-assess the consignments of the petitioner under Valuation Ruling No. 2008/2025 and release the same in accordance with law---Constitutional petition was allowed accordingly.

RAWAT OIL AND GHEE MILLS (PVT.) LTD. vs FEDERATION OF PAKISTAN through Secretary (Revenue)/Chairman FBR Ss — 2026 PTD 291 KARACHI-HIGH-COURT-SINDH

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