Customs exemption fails when withdrawn before import arrival; duty liability arises on the date goods reach port.

Customs duty exemption under notifications issued under Section 25(1) of the Customs Act was unavailable where the notifications had been withdrawn before the imported stainless steel ingots and billets arrived at Bombay. Liability to customs duty and additional duty arose on the date of arrival, and the goods reached port after the exemption had ceased to operate. Promissory estoppel could not be invoked to preserve a benefit that was no longer in force when duty became payable, so the levy of customs duty and additional duty was upheld.

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Issues: Whether the petitioners were entitled to exemption from customs duty and additional duty on the imported stainless steel ingots/billets, and whether promissory estoppel could be invoked despite the withdrawal of the exemption before the goods arrived at the port.

Analysis: The exemption notifications issued under Section 25(1) of the Customs Act applied only up to 31 March 1982 and had been withdrawn on 28 February 1982. The goods reached Bombay on 13 April 1982, when the exemption was no longer in force. Since liability to duty arose on the date of arrival, the petitioners could not rely on the earlier notifications or on promissory estoppel to avoid duty.

Conclusion: The petitioners were not entitled to exemption, and the levy of customs duty and additional duty was upheld.

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