Customs circulars without statutory authority cannot override law, making duty demands based on them unenforceable.

Administrative customs circulars without statutory backing cannot curtail duty-free import benefits or override the governing law. The text states that Circular No. 19/2013 lacked force because it was not issued under any enabling provision, and that executive instructions, including circulars and guidelines, are unenforceable to the extent they conflict with statute. In the dialysis accessories dispute, this principle meant the customs demand founded on the impugned circular could not be sustained, and the assessees obtained relief.

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Issues: Whether a customs circular lacking statutory backing could be enforced to deny duty-free import benefit and override the applicable law.

Analysis: The appeals concerned classification and duty treatment of imported dialysis accessories. The Tribunal noted that the same circular issue had been considered by High Courts, which held that Circular No. 19/2013 had no statutory force because it was not issued under any enabling provision. Executive instructions, including circulars and guidelines, cannot prevail over statutory law, and any direction inconsistent with the law is unenforceable.

Conclusion: The impugned orders were set aside and the appeals were allowed.

Final Conclusion: The customs demand based on the impugned circular could not be sustained, and the appellants obtained the relief sought.

Ratio Decidendi: Administrative circulars without statutory authority cannot override or curtail rights conferred by law.

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