Concealment under Customs law requires more than covering contraband with a genuine consignment; confiscation failed here.

Mere use of plywood to cover contraband in a bona fide consignment did not amount to concealment for confiscation under Section 119 of the Customs Act, 1962. The decisive factor was the absence of substantial evidence linking the transporter to the contraband goods, and the statutory requirement of concealment was therefore not met. On that basis, the confiscation of the plywood was set aside and relief was granted to the appellant.

---

---

Issues: Whether plywood used by the transporter to cover contraband goods in a bona fide consignment amounted to concealment so as to justify confiscation under Section 119 of the Customs Act, 1962.

Analysis: The plywood consignment was found to be bona fide, and there was no substantial evidence linking the appellant with the contraband goods. The decisive consideration was that mere coverage of contraband by a legitimate consignment is not the same as concealment, and the statutory requirement under Section 119 was therefore not satisfied.

Conclusion: The confiscation of the plywood was set aside and the appeal was allowed.

---