Customs duty date turns on vessel entry inwards, not outer anchorage, for determining Section 15 liability.

For Section 15 of the Customs Act, 1962, the relevant date for duty on imported goods is ordinarily the date of presentation of the bill of entry, but an earlier-presented bill is deemed presented on the date of the vessel's entry inwards. Construing Sections 7, 8, 30 and 31 together, the HC treated "entry inwards" as the vessel's actual entry into the harbour after the import manifest and permission to unload, not its earlier presence at outer anchorage or within port limits. On that basis, the bill of entry was deemed presented on 23-12-1966 and the duty collected was valid.

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Issues: Whether, for the purposes of Section 15 of the Customs Act, 1962, the relevant date for determining the rate of duty on imported goods is the date of presentation of the bill of entry or the date of the vessel's entry inwards.

Analysis: Section 15(1)(a) makes the presentation of the bill of entry the normal relevant date, but the proviso deems an earlier-presented bill to have been presented on the date of entry inwards of the vessel. The expression "entry inwards" was construed in the setting of Sections 30 and 31, which link unloading to the grant of entry inwards after filing of the import manifest. Reading those provisions with Sections 7 and 8, and having regard to the practical conditions of unloading in the Madras harbour, the Court held that the statutory reference was to the actual entry of the vessel into the harbour and not to its earlier presence at outer anchorage or within port limits. The earlier Sea Customs Act provisions did not alter this conclusion under the Customs Act, 1962.

Conclusion: The date of entry inwards for Section 15 was 23-12-1966, so the bill of entry filed earlier was deemed presented on that date and the duty collected was valid.

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