JUDGMENT

Through this constitutional petition filed under Article 199 of the Constitution of Islamic Republic of Pakistan (the "Constitution"), the petitioner seeks issuance of a direction to Respondents Nos.4 and 5 for assessment of duty of its imported goods on the basis of the Valuation Ruling No.2011/2025 dated 17.07.2025 (the "Valuation Ruling").2. Briefly, the petitioner is in the business of import of various types of goods; for the purpose of the case in hand, the goods imported are ceramic and porcelain tiles (the "Consignment"), which have been imported by the petitioner from China. It is claimed by the petitioner that considering the petitioner's record of being a substantial contributor in the form of taxes and duties, the petitioner has been granted a license of a private bonded warehouse under Section 13 of the Customs Act, 1969 (the Act ). Learned counsel for the petitioner submits that the Director of Customs Valuation issued Valuation Ruling No.1972 of 2025 (the "Initial Ruling...