Belated customs duty payment attracts interest where imported goods for a 100% export-oriented unit remained duty unpaid and the project never commenced.

Interest was leviable on belated payment of customs duty for imported equipment intended for a 100% export-oriented unit project, because the goods remained duty unpaid during the relevant period and the manufacturing activity never commenced. The Tribunal treated delayed duty payment as attracting interest as a matter of consequence, and rejected reliance on claimed bona fide belief or the fact that exports ultimately did not take place. The cited circular and case law did not displace the liability arising from the delay, so interest on the delayed customs duty was payable by the assessee.

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Issues: Whether interest was leviable on the belated payment of customs duty on imported goods intended for use in a 100% export-oriented unit project that could not be commenced.

Analysis: The imported equipment and goods remained duty unpaid for the relevant period, and the proposed manufacturing activity never commenced. The object of the 100% export-oriented unit scheme was therefore not achieved. The Tribunal held that when duty is paid belatedly, interest follows, and the appellant could not avoid the consequence on the basis of a claimed bona fide belief or the fact that export did not ultimately take place. The cited circular and case law did not displace the liability arising from delayed duty payment.

Conclusion: Interest on the delayed customs duty was leviable against the assessee.

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