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EXCISE DUTIES — duty suspended movements of goods — movements not correctly discharged — appellant guarantor of movements — whether shown that goods arrived at intended destination and diverted thereafter or did not arrive — burden of proof — First-tier Tribunal finding that goods shown to have arrived in all but two cases — whether sustainable conclusion — no — jurisdiction of Upper Tribunal considered — appeal substantially allowed by casting vote of the presiding judge — decision re-made — save for one movement, none of goods shown to have arrived — respondent liable for duty as guarantor.