DMT or WMT basis for exports of Iron Ores

This ruling decisively settles a recurring controversy in customs valuation of iron ore exports, whether Fe content should be computed on WMT or DMT basis. 

The Court held that the applicable law is that which exists at the time of the taxable event, and since the exports in question predated the Finance Act, 2022 amendment, WMT methodology governed the assessment. It rejected the Revenue’s attempt to apply DMT-based valuation retrospectively, even in cases alleging fraud. 

The judgment reinforces three key principles: (i) taxable event governs applicable law, (ii) circulars and settled precedent cannot be bypassed, and (iii) valuation methodology cannot be altered retrospectively under the guise of investigation findings.