(1.) This appeal filed by the revenue under Sec. 130(1) of the Customs Act, 1962 (the Act) is directed against the order passed by the Customs, Excise and Service Tax Appellate Tribunal, Eastern Zonal Bench, Kolkata dtd. 31/12/2021.
(2.) The revenue has raised the following substantial questions of law for consideration :
(3.) We have heard Mr. Kaushik Dey, learned Counsel appearing for the appellant and Mr. Arijit Chakraborti, learned Counsel for the respondent.