JUDGMENT

SYED ARSHAD ALI, J.---This Custom Reference has been filed under section 196 of the Customs Act, 1969 ("Act") to call in question the judgment of the worthy Customs Appellate Tribunal Peshawar Bench dated 18.12.2018("Tribunal").2. Briefly stated facts of the case are that it was reported by the Superintendent, Customs (Audit), MCC, Peshawar that an audit of the record pertaining to DTRE Approval No.PESH/4252/02032011 of M/S RG Match Industries (Pvt.) Ltd. was conducted by an audit team. The contents of audit were discussed with the Management of the unit. The Management provided revised summaries and requested reconsideration of the documents provided at later stage. The audit team considered the said documents and accordingly revised audit report vide C.No. Audit/DTRE/66/2010/10863 dated 01.01.2014, the relevant portion of which is reproduced as under:i. Scope of DTRE. Under Rule 297(b), the DTRE user has to make value addition not less than 15%. This is the basic requirement (scope) ...