Drawback brand rates can be fixed on basis of averages, says expert

As per Para 4.43 of FTP, "Goods imported against Advance Authorisation Scheme, which are found defective or unfit for use, may be re-exported, as per Department of Revenue guidelines

We are filing our brand rate application, where we have made the DBK-I, DBK-II and DBK-IIA forms. When we make the worksheet, can we take average duties on several bills of entry under DBK-II and DBK-IIA, as we are unable to establish a one-to-one corelation or work out the duty incidence on the basis of first-in first-out basis? If so, can you support us with any specific instructions on this matter?
 
You can refer to Para 5b (iii) of CBEC Circular no. 21/94-Cus dated September 15, 1994, which says: “In many cases, DBK-II/III statements show procurement of different lots