Customs classification errors may be corrected through bill of entry amendment without first filing an appeal.

Amendment of bills of entry and correction of an inadvertent classification error may be pursued under Sections 149 and 154 of the Customs Act on the basis of documentary evidence already in existence at the time of clearance, without treating an appeal under Section 128 as the exclusive route. Self-assessment remains an assessment, but correction of a mistaken classification is not confined to appellate remedy and may be achieved through the statutory amendment mechanism where the error is clerical, arithmetical, or arises from accidental slip or omission. The refusal to process the amendment solely because no appeal had been filed was therefore unsustainable.

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Issues: Whether amendment of the bills of entry and correction of the classification of imported goods could be sought under Sections 149 and 154 of the Customs Act, 1962 without filing an appeal under Section 128 of the Customs Act, 1962.

Analysis: The dispute concerned an inadvertent classification error in the bills of entry. The governing framework permits the proper officer to authorise amendment of documents under Section 149 and to correct clerical or arithmetical mistakes or errors arising from accidental slip or omission under Section 154. The appeal reasoned that self-assessment is nonetheless an assessment, but modification of such assessment is not confined to appellate remedy under Section 128 and may also be achieved through the other statutory routes, including amendment of the bill of entry on the basis of documentary evidence already in existence at the time of clearance.

Conclusion: The rejection of the amendment request on the ground that no appeal had been filed under Section 128 was unsustainable, and the appellant was entitled to correction of the classification through the statutory amendment mechanism.

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