Customs broker verification duty under Regulation 10(n) is satisfied by reliable KYC documents, not continuous surveillance or physical checks.

Regulation 10(n) of the Customs Brokers Licensing Regulations, 2013 requires a Customs Broker to verify the IEC, GSTIN, client identity and the client's functioning at the declared address through reliable, independent and authentic documents, data or information. The obligation does not extend to supervising how government registrations were issued, nor to conducting physical verification of every client's premises or continuous post-verification surveillance. On the stated facts, the documents obtained, including IEC, GSTIN and KYC material, were treated as sufficient to discharge the regulatory duty, and later verification reports did not establish that the exporters had never existed at the relevant time.

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Issues: Whether the appellant violated Regulation 10(n) of the Customs Brokers Licensing Regulations, 2013 by failing to verify the IEC, GSTIN, identity of its client and the functioning of the client at the declared address using reliable, independent and authentic documents, data or information.

Analysis: Regulation 10(n) requires the Customs Broker to verify the correctness of the IEC and GSTIN, the identity of the client, and the functioning of the client at the declared address using reliable, independent and authentic documents, data or information. The obligation does not extend to supervising the correctness of the government officers' decision to issue IEC or GSTIN, nor does it require physical verification of every client's premises or continuous surveillance thereafter. The verification reports relied upon did not establish that the exporters had never existed at the time of export; they only indicated that they were not found to exist at the time of later verification. The documents obtained by the appellant, including IEC, GSTIN and other KYC material, were sufficient to discharge the regulatory duty.

Conclusion: No violation of Regulation 10(n) was proved, and the revocation of licence, forfeiture of security deposit and penalty could not stand.

Ratio Decidendi: A Customs Broker satisfies Regulation 10(n) when it verifies a client through reliable, independent and authentic documents, data or information; the regulation does not impose a duty to ensure the correctness of government-issued registrations or to conduct physical or continuous surveillance of the client.

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