3.1. Further, the Ld. Commissioner's reliance on Circular 36/2010-Customs dated 23.09.2010 is misplaced, as Section 149 of the Customs Act, 1962, imposes no restriction on such conversions. It has been consistently held by various judicial forums, including Tribunals and High Courts, that the conversion of a shipping bill under the duty drawback scheme to one under the Advance License scheme is permissible under the governing provisions. Importantly, such conversions have been allowed even though, in principle, they involve a transition from a less rigorous to a more rigorous scheme. Despite this upward shift in regulatory rigor, the conversion has been permitted, recognizing the objective of promoting legitimate exports and ensuring procedural fairness. Therefore, the appellant submits that the rejection of the conversion request in the present case is not in line with the consistent legal position and hence it merits reconsideration. Also, it is a settled legal principle that substantial benefits should not be denied on account of mere procedural lapses, especially when all core conditions of the scheme are fulfilled. In the present case, the Appellant held a valid Advance Authorization at the time of export, complied with all necessary requirements. Also, the appellant claimed
