ORDER

ATHAR MINALLAH, JUSTICE:--- Leave in this matter was granted vide order dated 06.8.2015 to consider questions of law that had arisen from the judgment of the High Court, dated 22.12.2014.2. The High Court had answered the questions of law proposed in the reference application filed under section 196 of the Customs Act 1969 ("Act of 1969") in favour of the tax payer and against the Department. The controversy was regarding determination of the correct classification of goods imported by M/s K.S.Sulemanji Esmailji and sons (Pvt.) Ltd., Karachi ("respondent-company"). The latter had imported twenty six consignments which were described at the import stage as "BOPP" Printed Laminated Packaging Film (Metalized) ["imported goods"]. The respondent-company was granted the facility of clearance of goods under the 'Automated Clearance Procedure,' which enabled the importer to clear the imported consignments without subjecting them to examination. Only in the case of two consignments was the norm...