Customs broker licence revocation fails where notice was misaddressed and no reliable material linked the broker to exports.

Revocation of a customs broker licence under the Customs Broker Licensing Regulations, 2018 requires reliable foundational material linking the broker to the impugned export transactions and alleged regulatory breaches. Where the broker consistently denies any connection with the exporters, the notice is sent to an incorrect address, and the record lacks verifiable documents such as shipping bills or other basic evidence, the allegations cannot be sustained. On the facts described, the absence of dependable proof connecting the broker to the exports made the conclusions on breach unsustainable, so the licence revocation and penalty were set aside and the appeal succeeded.

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Issues: Whether the revocation of customs broker licence and imposition of penalty under the Customs Broker Licensing Regulations, 2018 could be sustained when the broker consistently denied any connection with the impugned exports, the notice was dispatched to an incorrect address, and the record lacked verifiable foundational material linking the broker to the exporters.

Analysis: The allegations rested on sketchy and unverified material concerning excess RoSL disbursement and alleged non-response to communications addressed to an incorrect location. The broker had repeatedly denied handling the exports or acting for the exporters, and the shipping bills and other foundational documents necessary for effective rebuttal were not made available. In these circumstances, the licensing authority was required to ascertain whether the address and the export transactions were in fact connected to the appellant before fastening regulatory breaches. The absence of reliable foundational facts rendered the conclusions on breach unsustainable.

Conclusion: The revocation of licence and penalty could not be sustained and the appeal was allowed in favour of the assessee.

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