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Issues: Whether the Commissioner of Customs (Preventive) had jurisdiction to seize the rig in the Exclusive Economic Zone, issue the show cause notice, and adjudicate the demand of customs duty in respect of goods imported, assessed, and cleared by the proper officer of customs.
Analysis: The determination turned on the scheme of the Customs Act, 1962, particularly the definition of "proper officer", the appointment and allocation of customs officers, and the exercise of power under the notice and adjudication provisions. The relevant notifications showed that the Commissioner of Customs (Preventive), Mumbai was appointed for Mumbai, Thane and Raigad districts, while separate officers were notified for designated areas in the Continental Shelf and Exclusive Economic Zone. The Court held that once the Central Government had specifically designated officers for those maritime zones, the jurisdiction of other officers was excluded. The territorial limits of coastal districts could not be treated as extending into the designated areas of the EEZ, and neither administrative practice nor consent could confer jurisdiction where none had been statutorily assigned.
Conclusion: The Commissioner of Customs (Preventive) had no jurisdiction over the designated area in the EEZ for the impugned seizure, notice, and adjudication. The jurisdictional objection was rightly upheld.