Customs duty on liquid bulk cargo must be assessed on actual shore tank receipt, not bill of lading quantity.

Customs duty on liquid bulk cargo is chargeable only on the quantity actually imported, because the taxable event is completion of import and valuation must correspond to the time and place of importation. Where goods are lost, pilfered, or destroyed before import is complete, duty does not attach to that lost quantity. An earlier circular treating bill of lading quantity as determinative was inconsistent with this statutory scheme. The same principle applies to both specific-rate and ad valorem duties, so assessment must be based on the shore tank receipt quantity in India rather than the bill of lading quantity.

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Issues: Whether, for finalisation of assessment of liquid bulk cargo under customs law, duty is to be computed on the quantity shown in the bill of lading or on the quantity actually received in the shore tank.

Analysis: The operative legal position applied was that customs duty is chargeable on imported goods only when import is complete, the taxable event is import, and valuation must correspond to the time and place of importation. Goods lost, pilfered, or destroyed before completion of import do not attract duty on the lost quantity. The earlier circular treating load-port quantity as determinative was inconsistent with this statutory scheme, and the same principle governs both specific-rate and ad valorem duty. The quantity relevant for assessment is therefore the quantity actually received in India, as reflected by shore tank receipt.

Conclusion: Duty was required to be reassessed on the shore tank quantity and not on the bill of lading quantity; the contrary assessment could not stand.

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