Customs duty depends on the bill of entry date, and amended exemption notifications may validly apply to imports.

For imported goods entered for home consumption, customs duty is determined by the rate in force on the date the bill of entry is presented under the Customs Act. An exemption notification issued under delegated power can be amended or withdrawn, and an importer has no enforceable right to insist on continued exemption merely because an earlier notification existed when orders were placed. The objections based on lack of notice, Article 14, and promissory estoppel were rejected because modification of an exemption does not create a binding promise to keep the concession alive. The amended exemption therefore applied, and duty was chargeable by reference to the statutory date.

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Issues: Whether customs duty on imported goods had to be determined with reference to the date of presentation of the bill of entry, and whether the amended exemption notification could be avoided on the grounds of prior notification, absence of notice, Article 14, or promissory estoppel.

Analysis: Under Section 15(1)(a) of the Customs Act, 1962, the rate of duty applicable to imported goods entered for home consumption is the rate in force on the date the bill of entry is presented under Section 46 of the Customs Act, 1962. The Court held that exemption under Section 25(1) of the Customs Act, 1962 is a matter of delegated legislative power and an importer has no absolute right to continue to enjoy an exemption merely because an earlier notification existed when orders were placed. The goods had arrived after the amended notification came into force, so the relevant legal date was the date when the bill of entry could be presented. The objections based on want of notice, Article 14, and promissory estoppel were rejected, as the withdrawal or modification of an exemption notification does not create an enforceable promise to keep the concession alive indefinitely.

Conclusion: Customs duty was chargeable with reference to the date of presentation of the bill of entry, and the amended exemption notification validly applied against the importer.

Final Conclusion: The writ petitions failed because the duty liability was governed by the operative notification in force on the relevant statutory date, and the petitioners could not claim a continuing exemption or resist the levy on equitable grounds.

Ratio Decidendi: For imported goods entered for home consumption, the decisive date for customs duty is the date of presentation of the bill of entry, and an exemption notification issued under delegated power may be modified or withdrawn without creating an enforceable right to continued exemption.

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