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"10. The Foreign Trade Policy, it is well settled, is referable to
the provisions of Sections 4 and 5 of the Foreign Trade
Development and Regulation Act, 1992. The policy cannot be
2013 (290) ELT 481 (Del.)
amended by an administrative circular. The circular does not in
this case supplement the policy or fill up an interstitial space.
The circular imposes a substantive condition at variance with
the policy. VBC 13 wp4499.07-14.6 Where the Central
Government has considered it necessary to impose a
requirement of physical incorpor ation, such a condition has
been made expressly in other provisions of the Foreign Trade
Policy. For instance, in relation to advance plus licences
governed by the dut y exemption scheme, it has been stipulated
that an advance licence is issued to allow duty free importable
inputs which are physically incorporated in the export products
(paragraph 4.1.3 of the Foreign Trade Policy for April 2005).
Similarly, while issuing a n exemption notification in relation to
imports covered by advance licences, the Union Government in
its notification dated 10 September 2004 (Notification 93/04)
has specifically defined materials to mean raw materials,
components intermediates, consumables, catalysts and parts
which are required for manufacture of resultant products. No
such requirement was incorporated in paragraph 3.7.6 of the
Foreign Trade Policy. In other words, the condition that the
inputs which are imported must be used in the export of the
resultant product was not incorporated as part of paragraph
3.7.6 of the Foreign Trade Policy. In that view of the matter, it
is not possible to accept the contention of the Respondent that
the conditions which were imposed by the circular VBC 14
wp4499.07-14.6 date 8 May 2007 were implicit in paragraph
3.7.6 of the Foreign Trade Policy. We, therefore, come to the
conclus ion that the conditions which were stipulated by the
circular dated 8 May 2007 were ultra vires paragraph 3.7.6 of
the Foreign Trade Policy and Customs notification dated 8
April 2005 (Customs Notification 32/05).