Publication of subordinate fiscal notifications controls when higher customs duty can apply to filed Bills of Entry.

A subordinate customs notification withdrawing concessional duty does not operate against importers until it is published or otherwise promulgated in a manner that reasonably informs those affected. Where Bills of Entry were filed before the later notifications had been effectively communicated to the public, the earlier concessional notification continued to govern those entries. The operative effect is that higher duty under the later notifications could not be applied to the goods covered by the already filed Bills of Entry.

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Issues: Whether the customs notifications withdrawing concessional duty took effect against Bills of Entry filed before the notifications were made known to the public, so as to deny the benefit of the earlier concessional notification.

Analysis: The dispute turned on when a subordinate legislative change becomes operative. The governing principle applied was that a law or notification which requires compliance must be published or promulgated in a manner that reasonably informs those affected, and it takes effect from such publication or promulgation unless the parent law prescribes a reasonable mode of publication. On the facts, the later notifications were dated earlier but became known to the public only later, and the Bills of Entry had already been filed when the change had not yet been effectively communicated. The weight of judicial authority therefore supported the view that the earlier concessional notification continued to govern those entries.

Conclusion: The benefit of the earlier concessional customs notification was available to the appellants, and the higher duty under the later notifications could not be applied to the Bills of Entry already filed.

Ratio Decidendi: A subordinate fiscal notification does not bind affected persons until it is published or otherwise promulgated through a reasonable and effective mode of communication so that it can be known by those governed by it.

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